ML20155A310

Responds to NRC 880707 Request for Addl Info Re Decommissioning Plan.Info Includes Flooding Potential & Protection Requirements,Flood Conditions & Effects of High Water Level on Structures

ML20155A310
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	09/30/1988
From:	Taylor J DAIRYLAND POWER COOPERATIVE
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LAC-12692, NUDOCS 8810050276
Download: ML20155A310 (26)

Text

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T D DA/RYLAND 0 $/:=/ COOPERATIVE . e o sw . wsusr va w a cnosn wom www Es ms4r0 JAMES W. TAYLOR General Manager September 30, 1988 In reply, please refer te LAC-12629 DOCKET NO. 50-409 Document Control Desk U. S. Nucleni Regulatory Commission Washington, D. C. 20555 Gentlemen:

SUBJECT:

Dairyland Power Cooperative La Orosse Boldng hater Reactor (LACBhlt)

Provisional License No. DPR-45 1.ACBhlt Decommissioning Plan -

Answers to Request for_Aflitjotml Informatjon

REFERENCES:

(1) DPC Letter, J. Taylor to Document Control Desk (DCD)

(LAC-12460) dated December 21, 1987 (2) NRC Letter, P. Erickson to J. Taylor, dated July 7, 1988 (TAC- 66950)

(3) DPC Letter, J. Taylor to DCD (LAC-12584) dated July 18, 1988 (4) Additional Questions, Nos. 46 through 50, submitted by NRC Resident Inspector at LACBWR (5) DPC Letter, J. Taylor to DCD (LAC-12501) dated February 22,19fD1 (6) DPC Letter, J. Taylcr to PCD (LAC-12616) dated September 9, 1988 In our letters of December 21, 1987, and February 22, 1988, (References 1 *,5. respectively), Dairyland ;'cwer Cooperat ive (DPC) submitted the Decommissioning Plan and SAFSTOR Technical Specifications for NRC review and approval. In response, you submitted a list of 45 questions (Reference 2) to be answered by DPC with an August 15, 1988, deadline. Five additional questions (Reference 4) were submit ted by the LACBhlt NRC Resident Inspector, and in telephon, conversation with Mr. Peter Erickson, LACBWR Project Manager (NRR), a suggestion was rade that il questions be answered along with the original 45 submitted to DIC in the 'uly 7, 1988, letter.

SS10050276 890+30 I pc4 4 FDR ADOCk 05000409 (

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m Document Control Desk LAC-12629 Page 2 September 30, 1988 Because of the substance and nature of the questions, DPC requested snd received a revised deadline of October 1,1988 (Reference 3). On September 9,1988, a letter was sent containing answers to 28 of the questions (Heference G).

The answers to the rest of the questions are included in this letter.

It should be noted that the answer to question No. 50 was provided in the September 9th submittal in a discussion of related questions 32 and 33.

Some of the answers suggest changes to either Technical Specificativ,is or the Decommissioning P1an. If and when the answers ta tbese question', are accepted Dairyland will submit the appropriate pages with the required revisions to these two documents.

If you have any questions, please contact us.

Sincerely, DAIRYLAND P WER COOPERA IVE ll-//(' ~1

/s/ James W. Taylor, General Manager JWT:JDP:dh Attachment oc - Mr. A. Bert Davis, Hegional Administrator U. S. Nuclear Regulatory Commission, Region III Mr. Peter B. Erickson, Project Manager Division of Nuclear Reactor Regulatior U. S. Nuclear Hegulatory Comeission Mr. Ken Ridgway l

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A. Ec_comruissionipg Plan - SAFSIOR

1. p. 1-2. Sectinn 1 bWnMAI in nchiltion ta the teclanieni rensons givcn in thla nection for chaming SA15tW, a financial renson, particularly for plants like la Crosse that are being shut d<mn prior io projectni end-of-Jife, is Ihnt SAPSitW l period allows a<hfitional time to accueulate denwalsaloning funds. This renson wns implicitly statnf in Section 6. 7 runt should be mkirst to Section 1.1 for completeness.

1 i DPC RESNNSE l

A paragrsph will be adde d in Section 1.1 as follows:

The shutdown of LACBWR occurred before the full funding for DECON was acquired. The SAFSTOR period will permit the accumulation of the full DECON funding.

2. p. 2 -4, Sec t i on 2. 5. 2 Mk' MOT This section describes leninge frue the stninless atcel liner in the lhel Kieweet Stornge Well (IMW). Describe whether the contuminatol IMW wnter is collectnf to pervent triense offsite without monitoring ami possible pn> cessing. Provide data on the present IMW leakage rates arnt the ersx!mm concentrations of the trulionuclides. I'rovide also a safety analysis of the leakage. If IESW leakage is relensnt offsite, determine radiological conseguencem to ascertain whether therv are any safety implicalions. Discuss the history of the IFSW 1eakage amt what has been done runi whnt can be done to repnir it. Analyre the potential for an increase in the Icairnge ami potential offsite expmure nucrquerwes.

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I DPC REsiM SE l The leakage from the ruel Element Storage Well (FESW) at LACBWH is I

collected in the Reactor Building Sump. The sump is transferred to the [

} Waste Hetention Tanks which are both sampled and filtered prior to  :

release. They are also monitored during release. Leakage from the f

LACBWH TESW was reduced substantially from its historic levels by an j injection of epoxy into the gap between the FESW liner and the ,

j supporting concrete walls. The reduction was from 340 gallons per day

! to 49 gallons per day. The repair was performed in 1980. Measurements j since 1980 have ranged from 30 gallons per day to 110 gallons per day.

j The monthly averages for 1988 are: l" t

l February 52 gals. per day l March 49 gals. per day ,

1 Arril 56 gals, per day t

! May 50 gala, per day j i June 46 gals. Per day ,

July 52 gals. per day '

j August 34 gals. per day  !

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i A review of the radionuclides present in the Fuel Element Storage Well l leakage indientes they are well below the amount allowed in 10 CFR Part 20 and 10 CFR part 50, Appendix I (1.3 E-4 uCi/ml). The level of 1 radionuclide releases was measurably below Appendix I during operation l I and, since the LACBWR has been shut down pennanently, there should be no j i greater consequences to the environment in the future. The FESW leakage has always been part of the site processed water routinely released.

Further repairs are not contemplated as n are aware of no technique  ;

developed that would improve on the epoxy sealing method already used. [

l There does not appear to be any measurable increase in the leakage. A [

20-year history of monitoring the storage well leads to a reasonable  !

i assurance that no significant increase will occur. As no significant

) increase in leakage is anticipated, no potential offsite exposure j consequences could be determined. It should be noted, hm.ever, that as ,

i leakage is not to the outside environment and could be transferred there i j only by intentional action following sampling and filtering, the l potent ial offsite exposure consequences of an increase in leakage are

insignificant.

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3. p. 3-6, Section 3.4.4 & 3.4.G l i

AWE _WAT l'rovide a discussion an the effect of Mississippi River flomling during the SA151tW perimi, lhw will fuel pool cooling be sweintainal at the ',

various flomi levels und what level is all cooling cmusbility lost?

What will be the effects frew no cooling? If there is a vndloactive

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n lense to unrestricted arens through surface or groumt wnter, provide the source terar, unless you can demonstrate that the icw probnbility or risk negntes the need for evaluntion.

pPC_ R5SJ'0liSJ The maintenance of fuel neol cooling during a Design-Basis flood at d

I.ACBWR was included in the analysis done during the Systematic i Evalualion Program. (See attached subaittal of May 12, 1982.) Under Topic II-3.8.1, "Capability of Operating Plants to Cope with Design-Busis Flooding Conditions " the NRC concluded in their Final Haport of June 1983 (NUREG-0827) that:

"... emergency procedures and Technical Specification limiting

conditions for operation for site flooding and Mississippi River low

water level to complement use of the emergency service water supply system to cope with such conditions are not available. The licensee in a letter dated February 10, 1983, proposed to develop emergency  ;

procedures to cope with a flood elevation of 658 f t mean sea level i (htSI.) in nddit ion to 3-f t wind waves to GG1 ft, which are consistent l with current licensing criteria. The necessary procedures are scheduled to be developed by Ja' . ry 1984. The staff finds this ,

action and the proposed schedule acceptable."  !

! The procedure referred to in this report was completed in 1984 and will ,

continue to be a part of the facility procedure 9 during the SATSTOR r period. This procedure includes provis. ions for keeping the stored fuel cooled by addition of water from tha overhead storage Tank (011sT) if and when required, the procedure also provides a method of using a portable, gasoline engine driven pump to provide makeup water to the OllST should all of its water be used. Ti,cre should be rio river level attainable, therefore, which would cause all cooling capability to be r lost.

Calculations done by the LAcilWR heuctor Engineer show that , i f FESW  !

cooling was lost, it would t ake over 8 days for water temper ature in the j well to reach the boiling point. Subsequent ly, a period of great er t han ;

40 days would elapse befot e the FESW water level would decrease to a point where the top of the irradiated fuel would be exposed. Therefore. '

. the probability of a flood causing adverse effeeta to the atored fuel r.t '

LACBWR in extremely remote.

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DlDA/RYLAND

) h / COOPERA T/VE eo 00: sir . reis tist Av coutn . tA caosst wisconsin ses0i t006) 7884000 May 12, 1982 In reply, please refer to LAC-8283 DOCKET NO. 50-409 Director of Nuclear Reactor Regulation ATTN: Mr. Dennis H. Crutchfield, Chief Operating Reactors Branch 45 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 SU BJECT: DAIRYLAND POWER COc/ERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)

PROVISIONAL _ OPERATING LICENSE NO. DPR-45 SEP TOPICIII-3. O- FLOODING POTENTIAL AND PROTECTION REQUIREMENTS, SEP TOPIC II-3.B.1 -

CAPABILITY OF OPERATING PLANTS TO COPE WITH DESIGN BASIS FLOODING CONDITIONS, AND SEP TOPIC III-3.A - EFFECTS OF HIGH WATER

} LEVEL ON STRUCTURES (REVISION 1)

References:

1) DPC Letter, LAC-7387, Linder to Eisenhut,

, dated February 27, 1981.

2) DPC Letter, LAC-8146, Linder to Eisenhut, dated March 9, 1982.

i Gentlemen:

l Enclosed please find the combined Safety Evaluation Reports of Flooding l Potential and Protection Requirement, and Capability of Operating Plants to Cope with Design Dasis Flooding Conditions (SEP Topics II-3.B and II-3.B.1); in addition to a resubmittal of Safety Evaluation Report Effects of High Water 14 vel on Structures (SEP Topic III-3.A, Revision 1).

Resubmittal of SEP Topic III-3.A is being made in order to bring this Safety Evaluat. ion Report into agreement with the Flooding SEP Topics II-3.B and II-3.B.1 which address the precautionary neasure of pressur-izing the reactor containment building rather than flooding to maintain structural integrity during Flood Crisis conditions. In addition, an unnecessary and incorrect discussion regarding the Maximum Probable Flood (HPF) has been eliminated from the S4P Topic. SEP Topic III-3.A was first submitted by DPC per Reference 2.

t T Our letter, Reference 1, identified topics for DPC to submit for NRC

/ evaluation. The subject topics were listed in the schedule submitted with Reference 1.

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I Mr. Darrell G. Eisenhut, Director May 12, 1982 Division of Licensing LAC-8283 If there are any questions regarding these reports, please contact US.

Very truly yours, DAIRYLAND POWER COOPERATIVE Frank Linder, General Manager FL:DLReaf Enclosure cc J. G. Keppler, Reg. Dir. , NRC-DRO III NRC Resident Inspector

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1 j i LA CROSSE BOILING WATER REACTOR l u i SEP SAFETY ASSESSMENT REPORT i 4

TOPIC 11-3.8; FLOODING POTENTIAL AND PROTECTION REQUIREMENTS  !

and i 3

TOPIC 11-3.8.1; CAPA8ILITY OF OPERATING PLANTS TO COPE WITH DES!GN BA5I5 FLOODING CONDITIONS '

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1.0 INTRODUCTION

, The objective of this topic is to assure that structures, systems and components required for safe shutdown are adequacely protected against

) floods. This topic reviews the flooding potential and describes the i

j corresponding protection requirements, i

2.0 CRITERIA Criterion 2 of the General Design Criteria of 10 CFR 50. Appendix A covers

! flood protection of nuclear power plant. A restatement of Criterion 2

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follows.

{ Criterion 2 - Desgin Bases for ;rowction Against Natural Phenomena -

Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes.

1 i - tornadoes, hurricanes, floods, tsunaal, and seiches without loss of capability to perform their safety functions. The design bases for these structures, systems, and components shall reflect (1) appropriate l consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area, with suffletent margin for the limited accuracy, quantity and period of time in which the historical data have been accumulated. (2) appropriate combinations of j the effects of normal and accident conditions with the effects of the

) natural phenomena and (3) the importance of the safety functions to be performed.

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3.0 BACKGROUND

The LACBWR site was originally designed to a specified, minimum flood reoccurrence interval of 100 years. Plant grade was established at Elevation 639 feet mean sea .evel and the foundation elevation of each significant structure was located at or above Elevation 640 feet. Both of these elevations exceed the 100-year reoccurrence flood Elevation 636.8'. Therefore, the design basis flood for the LACBWR site c.)rresponds to the flood which produces a surface water elevation at nomimal station grade. Elevation 639 feet.

The hydrologic description of the LAC 8WR site is provided in the Safety Evaluation Report (SER) Topic !!.3.A, "Hydrologic Description."4 This SER indicates that safety-related structures at the LACBWR site have their grade-level access points and floors above the predicted water elevations for

.) floods up to a 500-year reoccurrence interval. Safety-related structures for the 1.ACBWR site are identified in SER Topic !!!-6, "Seismic Design Considerations ." 7 4.e DISCUSSION

- Dairyland Power Cooperative (DPC) has long recognized the flood potential at the LACBWR site. In 1969 DPC implemented a flood control program which included establishing contact with local governmental agencies, instigating flood condition operations, procurement of flood control equipment and materials, and adopting measures for the construction of temporary dikes at the LACBWR site if required.

With regard to the contact with local governmental agencies, OPC has established an interface agreement with the U. S. Army Corps of Engineers and

) receives flood forecast data from the U. S. National Weather Service Forecast Office, in 1976, the Corps of Engineers issued Directive No. 1001 which WP.1 2 -

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establishe: comunications between DPC and the Corps of Engineers regarding i the LAC 8WR site. In addition, the directive establishes a cooperative 1 agreement between Corps personnel assigned at the lock and dam in the imediate vicinity of the LACBWR site and OPC. This agreement addresses communications during environmental emergencies and the use of emergency facilities including small craf t. The U. S. Anny Corps of Engineers has

! establithed a set of warning stations throughout the upper Mississippi River basin. These warning stations are gene. ally established at locations that are 1/2 te 1 day travel time above the mouths of tributary streams. On the larger i

tributaries, additional warning stations have been established, providing all areas of the Mississippi River several days warning of approaching flows.

These warning stations together with routing calculations perforr:cd by the Corps of Engineers and the three-day flood forecasts as issued by the U. S.

) National Weather Service flood forecast center provide OPC with adequate I

information in a timely fashion.to. instigate the appropriate level of. flood -

i 1 protection measures at the LACBWR Site. -

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In}'thedeventdof,[a[ flood or[p'otential. fl,o,od, conditions,0PC woIJ1dit phment'

,4 + proce,du [esy o'! cover.f . con iti, e'r'aEi s eie'pr'oce'duresv'giip-we 4'-

dependent)on ithe' predicted' flood' conditions and actual river stages'a't' the LACBWR site. The various flood condt.ty.t. the corresponding river stages, and a sumary of qthe; planned p ,

edures are sumartzed on Table 133.8.1. On ,

the averge, a floodNiert.could be expected to occur coce every three ears. .

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%t . , 3 di ;$ operattons. OPC' maintains'at the Genoaf.s( " f,$ d '.

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(floo gib $.h\%_ p i i ' .) . O a .; v,ynW .

flood protection eMtpinent and'ma'terials such as' portable pumps, sarid%ag;s, '

) rolls of ' plastic sheeting, and miscellaneous hand tools. Construction of .

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emergency flood control levees and dikes would conform to the U. S. Army Corps of Engineers recomended methods for such structures.

As indicated on Table 11-3.8.1, the construction of temporary dikes would begin when the river stage surpasses 635 feet. The tmporary dike constrettion would consist of a set-back levee which would enclose the reactor and turbine buildings. The height of the levee would extend approximately 3 feet above the predicted flood stage to account for the uncertainty of flood stage projections and the effects of wind. generated waves, it is estimated that the maximum practical height of a temporary levee for the LACBWR site is an elevation of 646 feet. The elevation of 646 feet corresponds to the following site features:

• At Elevation 643 feet. the river stage is approximately 4 feet above plant grade. Such a water depth would not support significani; flow in and around plant structures, thereby eliminating the potential of floating debris from affecting the temporary dike or protected structures should the temporary dike fall.

• Access to the containment vessel through the emergency air lock would still be possible should the temporary dike fail. The sill for the lock is elevation 645 feet.

• An ESWS$ pump which would supply makeup water to the shut down condenser during such a flood would be located on the dry side of the temporary dike. Backup ESWSS pumps would be located at elevation 654 in the Turbine Building. These backup pumps would therefore be protected frors the ef fects of topping or failure of the dike.

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1 A fully developed flood emergency dike is able to protect the LACBWR site from a flood comparable to a Standard Project Flood (SPF). The SPF for this region is based on estimates of the most critical combinations of snow, temperature, and precipitation considered reasonably characteristic of the region. A SPF estimate reflects a generalized analysis of flood potentials in a region as contrasted to an analysis of flood records at a specific site. A flood solely derived on historic data at a site may be misleading because of inadequacies of records or abnormal sequence of hydrologic events during the period of stream flow observation. For LAC 8WR, the standard project flood was detennined by increasing the standard project flood at La Crosse, 'Sconsin of 375,000 cubic feet per second2 by a ratio of the increase in the ,espective drainage areas. La Crosse is approximately nineteen miles upstream of LACBWR site. This corresponds to approximately a three percent increase in drainage

} area betweet the LACBWR site and La Crosse. This calculation results in an estimated flood at the LACBWR site of 386,000 cubic feet per second. As can be seen in Figure !!-3.8.1, the estimated river Al 'vation for the standard project flood at Lock and Dam Number 8 is 643.2 feet. Since the LACBWR site 1.5 approximately 2000 feet below Lock and Dam Number 8, it is conservative to use the SPF flood stage for the Lock and Dam at the LACBWR site.

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TABLE !!-3.B.1

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FL000 CONDITION OPERATIONS FLOOD CONDITION RIVER ELEVATION KEY OPERATION Flood Alert 630(1) Alert OPC management.

Initiate special inspection routines.

Initiate continuous monitoring of flood forecasts.

Plan flood control operations.

Assure availability of equipment and materials.

If required based on flood forecast, mobilize personnel for dike construction.

Flood Warning 635(1) Start temporary dike consteuction and install pumps.

Coordinate flood control operations with Corps of Engineers, Lock and Dam No. 8.

Flood Emergency 639(1) Continue temporary dike construction.

Shut down LACBWR.

Flood Crisis 643(2) Shut down LACBWR (if not previously shut down.

Depressurize tne reactor f.colant system and initiate core cooling with the shut down condenser.

Initiate pressurization of containment vessel.

Initiate installation of containment protective apron.

(1) Flood condition to be initiated based on actual river stage.

(2) Flood crisis to be initia.ed based on three-day flood forecast.

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A probability versus flow curve for Lock and Dam Number 8 and

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correspondingly, the LACBWR site is shown in Figure !!-3.B.2.

The probability of occurrence based on historic flows of a flood comparable to the SPF in any given year is approximately 4.1 x 10-4 The maximum rate of rise of the Mississippi River at La Crosse during a SPF is predicted to be 1.6 feet per day 2. Due to the approximate location of the LACBWR site to La Crosse this rate of rise is considered applicable also to the site. As previously noted, flood forecasts will be closely monitored begining with the declaration of a flood alert. These forecasts are precominately the three-day flood forecasts issued by the U. S. Weather Bureau Flood Forecast Centers. Considering the predicted rate of rist for a SPF,

, approximately 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> would be available between the declaration of a flood alert and the i etion of flood warning measures. This time is sufficient to plan specific flood protectiye actions, verify inventories of materials and

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supplies, and mobilize personnel. There will be approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> and 123 hours0.00142 days <br />0.0342 hours <br />2.03373e-4 weeks <br />4.68015e-5 months <br />, respectively, between the flood warning.(start of dike construction) and the flood emergency stage and between the flood warning and the crest of a SPF. This is ample time to construct the temporary dike and take other mitigathe actions.

In the event that the three-day flood forecast projected crest exceeds Elevation 643 feet, DPC would instigate "flood crisis" measures, in summary, flood crisis measures include:

(1) Immediate shut down of the reactor (if not already shut down).

(2) Set up an ESWSS System Pump to provide makeup water to the shut down condenser, t (3) Primary system cool down and depressurization via normal operation until such time that the shut down condenser is capable to accomodate decay heat.

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) (4) Initiation of pressurizing the containmnt vessel by means of on-site compressors to a pressure corresponding to a water level approximately 3 feet above predicted peak flVer stage plus an allowance for containment leakage.

(5) Installation of temporary protective apron around the exterior of the containment vessel up to approximately 3 feet above predicted peak river stage.

(6) Location of ESWSS pumps in a position at least 3 feet above predicted peak river stage.

(7) Installation of a temporary DENIN/HPSW/ESWSS fuel pool makeup line to backup the overhead storage tank makeup to the fuel pool storage well .0 These actions will; (1) provide for long-term core and spent fuel pool cooling, (2) protect the containment vessel from the external pressure due to the flood and construction of protective apron and, (3) maintain the containment vessel integrity. Pressurizing of the containment vessel up to 48 psig is an existing design consideration for the containment vessel 5 . Therefore, the

) effect of pressurizing the containment vessel has already been considered in the design of LACCWR facilities. An example of the containment ability is i demonstrated by the following analysis. The internal pressure required to compansate fcr a surface water elevation of 650 feet plus 3 feet of margin is l 11.6 psig.

This pressure would have to be maintained through the crest of any i

flood. Allowing for a 16 day period for the crest of the flood to pass and the design leakage rate of 1 percent per day, the required pressure would be l 20.6 psig. This is significantly less than the design pressure of 48 psig.

Based on this analysis it is clear that pressurization of the containment .

i vessel can accommodate flood levels significantly greater than elevation 650 feet and for periods longer than 16 days.

l It is believed that the outlined actions will adequately protect the LACBWR facilities from the effect of floods which may exceed the SPF. For a

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tlood greater than the SPF, flow in and around plant facilities would increase WP-1 -__ - - - - - - - . . , - . _ _ . _ _ _ __ - ._ - - -

over that flow expected for a SPF. However, the protective apron around the containment vessel will protect the vessel from contact with any debris which may clear the temporary set back dike and other permanent facilities. Access to the exposed portions of the turbine building which would house the ESWSS ,

pumps which would provide core cooling and spent fuel pool makeup will be provided via small river craf t.

5.0 CONCLUSION

S It is the conclusion of DPC, that the above discussion demonstrates the

adequacy of the LACBWR site to withstand the effects of floods without the loss of capability to perform their safety function.

1 The above LAC 8WR procedures would maintain the station in essentially a dry condition for a flood of magnitude comparable to a standard project flood.

This flood provides sufficient margin over the historic flood of record to account for any uncertainty in the data, it is also concluded that the flood crisis actions outlined in this response to deal with floods larger than standard project flood are appropriate.

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6.0 REFERENCES

1. 10 CFR 50, Appendix A.

2. Flood Plain Information, Mississippi River and Tributaries, La Crosse, Wisconsin, April 1970.

3. "Upper Mississippi River Water Profile River Mile 0.0 to River Mile 847.5", by Serview, November,1979 prepared by the U. S. Army Corps of Engineers for the Technical Flood Plain Management Task Force of the Upper Mississippi Basin Commission, as interpreted by Warren Gebert, U. S. Geological Survey, Madison, Wisconsin to John Parkyn, Dairyland Power Cooperative, April 30, 1981.

4. Dairyland Power Cooperative Systematic Evaluation Program, Safety Evaluation Report, Topic !!-3.A. "Hydrologic Description."

5. Dairyland Power Cooperative Systematic Evaluation Program, Safety Evaluation Report, Topic 111-7.0, "Containment Structural Integrity Tests."

6. Dairyland Power Cooperative Systematic Evaluation Program, Safety Evaluation Report, Topic, IX-1, "Fuel Storage."

7. Dairyland Power Cooperative Systematic Evaluation Program, Safety Evaluation Report, Topic III-6, "Seismic Design Considerations."

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LA CROSSE BOILING WATER REACTOR

- SEP SAFETY ASSESSMENT REPORT TOPIC III-3.A: EFFECTS OF HIGH WATER LEVEL ON STRUCTURES REVISION 1

1.0 INTRODUCTION

The objective of this topic is to assure that, if the high water level for the plant is reevaluted ano found to be above the original design basis, the plant structures can withstand this water level.

2.0 CRITERIA Criterion 2 of the General Design Criteria of 10 CFR 50, Appendix A covers flood protection of nuclear power plants. A restatement of Criterton 2 follows.

Criterion 2 - Design Basis for Protection Against Natural Phenomena .

Structures, systems, and components important to safety shall be desi;ned to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. The design basis for these structures, systems, and components shall reflect: (1) appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area, with sufficient margin for the limited accuracy quantity, and period of time in which the historical data have been accumulated, (2) appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena and, (3) the importance of the safety functions to be performed.

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i-9 3.0 BACKGROUNO

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, The hydrologic description of the LACBWR site is provided in the Safety Evaluation Report (SER) Topic !!-3.A. "Hydrologic Description 2, and SER Topics 11-3.B, "Flooding Potential and Protection Requirements"3 and !!.3.B.1, "Capability of Operating Plants to Cope with Design Basis Flooding C ondi t i ons ." 3 These SER documents indicate; (1) that the original design basis flood for the LAC 8WR site corresponds to the flood which produces a surface water elevation at nominal station grade. Elevation 639 feet mean sea level, (2) that safety-related structures, as defined in SER Tootc III-6, "Seismic Design Considerations"4, have their grade-level access and floors above the predicted water elevations for floods up to a 500-year occurrence interval, (3) that the site can be maintained in a dry condition by means of temporary dike construction for a flood which equals the standard project flood, and (4)

) that the LACBWR facility can be shut down and maintained in a safe shut down condition for floods significantly greater than the standard project flood.

4.0 O!SC09S!0N The structures at the LACBWR site are designed for hydrostatic pressure and the associated bouyancy effects of water level at plant grade or elevation 639 feet 2. Based on the SER Topics !!-3.B and It-3.8.1 the LACBWR structures

! inside the temporary dike would be protected, i.e., maintained in a dry l

) condition, from floods with an equivalent stage of up to 646 feet (flood l stage 643 feet plus 3 feet of free board). The crib house which is located i on the river could not be practically protected beyond a river stage of elevation 640 feet. However, oased on the capability of the shut down condenser and the Emergency Service Water Supply System (ESWSS) to remove l

) decay heat and provide makeup to the spent fuel pool on a long-tem basis, the

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loss of service of this st,ucture is not judged to be critical.

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Therefore, the use of the flood emergency measures as outlined in SER Topic 11-3,.83 maintains the original design basis of the critical structures.

For floods which would exceed an equivalent river stage of elevation 646 feet, flood crisis conditions would be implimented. With respect to structures, the pressurization of the containment vessel will stiffen the vessel to accommodate any external pressure which would be associated with the construction of the temporary apron around the vessel or the hydrostatic ef fects of the flood waters. As noted in SER Topic !!-3.83 , an internal pressure of 20.6 psig would adequately protect the containment vessel from the external pressures due to a flood level of 650 feet for a period of 16 days with a leakage rate of 1 percent per day. Since the design pressure for the containment vessel is 48 psig, it is clear that pressurization of the containment vessel can accommodate flood flows significantly greater than

) elevation 650 feet and for periods longer than 16 days.

The construe. tion of the protective apron around the exterior of the containnent vessel as part of the flood crisis actions will protect the vessel from beceming impacted by floating and tumbling debris and from variations in hydrostatic pressure due to the flow of water.

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Bouyance of the containment vessel is adequately accomodated by the dead weight of the structure. The minimum dead weight of the containment vessel is 17,366,000 pounds. Each foot of heicht of the coatainment vessel displaces 2,827 ft3 or 176,430 pounds of water. Therefore, toe dead weight of the vessel can accomodate up to 89.5 feet of hydrostatic head considering a 1.1 factor of safety against floatation. The bottom of the containment vessel foundation is elevation 609 feet 6 inches. Therefore, the minimum availabla dead weight of the containment vessel will accomodate a flood elevation of 699 feet.

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Other structures at the LACBWR site are vented and not designed to be I

watertight. Therefore, at flood elevations above 646 feet, the lower portions of these structures would be flooded. Howeve: , due to the protection of the containment vessel and the portable, redundant nature of the ESSWS pumps, flooding of these structures is not considered significant in providing adequate core cooling or makeup to the spent fuel pool.

5.0 CONCLUSION

S It is the conclusion of OPC, that the above discussion demonstrates the adequacy of the containment vessel to withstand the effects of floods without the loss of capability to perform its safety function. The LACBWR procedures summarized herein would maintain the station in essentially a dry condition for a flood of magnitude comparable to a standard project flood. This flood provides sufficient margin over the historic flood of record to account for

) any uncertainty in the data. Additionally, DPC concludes that the flood crisis actions cutlined in !! .3.83 to deal with floods larger than a standard i project flood are appropriate.

6.0 REFERENCES

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1. 10 CFR Part 50, Appendix A. I

2. Dairyland Power Cooperative, Systematic Evaluation Program, Safety Evaluation Report Topic !!-3.A. "Hydrologic Description."

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3. Dairyland Power Cooperative, Systematic Evaluation Program, Safety Evaluation Report Topics 11-3.B, "Flooding Potential

, and Protection Requirements," and IL-3.B.1, "Capability of j Operating Plants to Cope with Design 7affs Flooding Conditions."

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4. Dairylar.d Power Cooperative, Systematic Evaluation Program, Safety Evaluation Report Topic !!!-6, "Seismic Design l Considerations." '

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4. p. 3-7, Section 3.4.7 AWC COWENT This acction abould niso address the effects of high water (loss of pumps) on the ultimate heat sink. Sec question 3 above.

DPC RESPONSE See response to Question No. 3.

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10. p. 6-11, Section 6.7 NAC COINrNT The statement is ande in Section 6. 7 that "A later dismantling date will allow additional funds to accueulate to compensate for the cost of inflation. " This in generally true but it presupposes that the inflation rate for decommissioning cost will be less than annual rate of interest carnings on the decommission fund. In support of this aml similar statements such as on page 6-13, the licensee should provide the assunctions of and bases for inflation and irterest rates usalin the '

Decommissioning Plan.

DPC HESPONSE In support of the current funding policy for its decommissioning fund, Dairyland has based its assumptions of inflation and an interest '

earnings rate on historical information, along with prospective forecasts and the resulting differential between these two factors.

Dairyland believes that the historical inflationary trends are best "

represented by the Gross National Product Implicit Price Deflator (GNP).

During the past 10-year period ending in 1987, the GNP rate has averaged 5.8% which included the high inflationary period from 1978 through 1982 i and the recent low inflationary period of 1983 through 1987. ,

During the same time frame of 1978 through 1987, the 13-week Treasury Bills and the 3-5 year Trensr.ry Notes bave yielded an average rate of 9.1% and 10.4% respectively. The tenult has been a differential in yield of 3.3% assuming Treasury Bill investments and 4.6% nssuming 3-5 year Treasucy Notes. Adding the five-year tima frame of 1973 through 1978 results in a 15-year overage GNP rate of G.4% with 8.2% and 9.4%  ;

Treasury Rates, yielding an inflation / interest differential of 1.8?. and j 3% respectively. Dairyland's ir. vestment policy resultu in a mixture of both short and medium tenn investants in U.S. Trea9urles Obligatians, thus the 13-week and 3-5 yeer treasurb o are on appropriate reflection of the fund's earning potential.

P through a financial advisory relationship, Dutryland's current t inflationary estimato for its overall corporate financial plan is 5% i which is supported by a 20-year trend forecast averaging 4.5% from a  !

well recognized econometric forecasting service, Data Resources. Inc.

• However, Dairyland's most current estimate of inflation through 2010 ,

used in establishing its current level of decomissioning funding i conservatively was increased to 6% from the 4.5% to 5% inflationary .

rates mentioned above.

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The DRI forecast also projects a 20-year trend of the 13-week Treasury I

Bills at an average rate of G.4% and the 3-5 year Treasury Notes at a rate of 7.9%. This produces a yield differential of 1.9% and 3.4% from the 4.5% DRI forecasted inflationary trend. Dairyland's interest rate asstnaption for its deconuaissioning funding has been estimated at 7.0%,

again a conaervative estimate for the next 20 years resulting in an inflation / interest differential of only 1%. This minimal differential is also supported by Dairyland's actual yield in 1987 of 6.0% while the GNP price deflator was 3.3%, resulting in an inflation / interest differential of 2.7%.

The deconanissioning funding estimato is thus based on a conservative differential between inflation and interest rates of 1%, with inflation of 64 being estiinated higher than expectations of others while the

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interest assumption of 7% falls well within expectations. The key factor is that the interest earned from the decoimaissioning funds will be paid back into the fund to compensate for the cost of inflation. The very conservative differential of 1% between interest rates and inflation has produced a deconnaissioning fund plan forecast with '

continued annual funding of $1.3 million through 1999 which results in adequate funds being available by 2010 to match the current deconcaissioning cost adjusted fer inflation through 2010. As circumstances change, the coat of deconanissioning, the inflationary factor, and the earnings factor will be studied and adjusted at least on a five-year basis. The Dairyland Board has indicated that it will adjust the decommissioning fund accumulation as necessary, be. sed on the results of these studies.

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11. p. 6-12, Section 6.7.1 NRC CMNT The listing af SA15%H costa is confusing and perhafw too cryptic.

NUJniW/CR-0672 "Technology, Safety and Costs of Deccanissioning a hkference Bolling Water Reactor Powr Statlon" indicales that for a large commercial BWR, preparation for safe storage would cost appravi-antcly $21.3 millitm in 1978 dollars with continuing carn during the SA151DR period costing $75,000 per year. NURhYi/CR-0672, Addendem 3, which will update the 1978 c<ata to 1966 dollars will be availabic in early July 1988. Allowing for La Crosse's sen11 size, the preparation-for-safe-stornge costs appear low although not unreasonable. Given that spent fuel will be stored on-site during the SAISNR period, it wuld be expected timt annual ccmts during the SAFS1tW period wuld be consider-ably higher than indicated in NURhTi/CR-0672. With inforantion provided in the plan howver, there is no way to determine how reastumble the annual casts figures are. It wuld be helpful to have a more detailed breakdown of costa, particularly of ba.se yc sr costs, as wil as explicitly stating the escalation factor for the annual costs.

DPC HESPONSE The estimated conta for SAFSTOR for 1989 consisted of the following, broken down by actual function, as was the case with the information provided in the Decommissic,ning Plan. These are the types of functions which have always been useri in utility budgeting:

. Wages - $1,350,000 The wagen cover actual employee remuw' ration, both regular hcurs worked und overtime for administrative and bargaining unit personnel.

. Fringe Benefits - $540,000

' The fringe benefit packago is calculated based on the wages for employees as referenced in the previous itern.

. Employee Expenses and Training - $18,000 These expenses consist of employee attendance at seminars or training sessions as well ns travel for professional and business purposes. This category includes travel, meals nnd lodging.

. Communications Cost - $20,000 This item covers the cost of local telephone service, long distance telephone service and facsimile transinission costs.

. Equipment Costs - $75,000 This category includes the costs for the purchnne of new or replacement equipment in order to maintain the facility's enpubilities to operate systems still running nod nualyze environmental releases.

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. Material and Supplies - $105,600 This category includes all supplies purchased in support of the SAFSTOR activities at LACBWH of a non-equipment nature. This includes consumabls supplies used on a day-to-day basis and those .

purchases drawn from Dairyland warehouse stores as well as f purchases made outside the system.

. Outside Services, including Security - $400,000 i This category includes contractual services for maintenance of equipment, fees paid to the Nuclear Regulatory Commission and state '

government, services provided by the contractor guard service, consultant time for design oversight and review, fees and expenses paid to members of the offsite Safety Review Committee, and any other non-material oriented expenses generated which are not covered by the preceding categories.

The rate used as an escalation factor for the annual costs is 4.8L -

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12. p. 6-13, Section 6.7.2 l NM coverNT i in the paragraph addressing the 5 year synintes of decamelssioning costs estienten, it mudd be nppropriate to have a statement to the effect {

tJmt the Board of Governors of kulryland Pbe,cr Cooperative agrees to >

f' increase Dalryland's decomelasjoning fund contribution by the neount  :

indicated by the ccwi atudy update.

' 1 DPC RESPONSE The Board of Directors of the Dairyland Power Cooperative passed a f' resolution at its August board meeting in response to this questinn, as follows:

• 1 "WHEREAS, at its meeting of Deceinber 16, 1983, the Board of  ;

Directors of Dairyland Power Cooperative (Dairyland) resolved to ensure

, that adequate funding would be available at the time of decomunissioning [

to cover the cost of decommissioning the La Crosse Boiling Water '

{ Reactor (LACBhTl) facility; and

"WHEREAS, the Board of Directors at that time adopted a specific

funding plan and further resolved to regularly review the adequacy of j that funding plan, specifically conteinplating that as a result of j detailed study, additional experience, or chenged regulatory require- ,

ments, a change in tive leve) or strv:ture of funding for decomissioning  ;

l might be necessary la the future; e.ad i 1

"WHEREAS, Dalrylar.d has sub.sitted to the !4uclear *Ingulatory i Com.nission a Decomreissioning Ple.n thai, among other things, is required i to assure the willaM1ity of adequate fuisda for 1ecommissioning and, toward that cud, undertakes to upd. ate the deccamientonitig cost estiarate j ever- five yeers during the SAFSTOR period, the first update to occur in  ;

1988, 4

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) "NOW, TilERENRE, f4 IT RESr1NED, that the Boned of Directors of l 1 Dairyland re-aains committed to assur6g the.t adensate funaing will be

] avnflah?.c for the decommissicr.ing of the LACBhTt facility, and is pre-pared to atyust the funding level for the LACBWR decommissioning plan from t;we co time, and/or take such other actions ns it deeres necesacry a or appropriate to provide such assurance, based upon its review of the

! - most recent decomissioning cost estimate and other relevant develop-

]

ments in this area."

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A statement sumanarizing the above resolution will be added to the i

Decocaissioning Plan.

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15. p. 8-2, Section 0.2.2 EW CM6h?

Provide watmes of the principal decoeurissioning and decontamination staff.

DPC RESPONSE The resumes of the management and professional staff responsible for decommissioning are as followu:

Plant Superintendent: Bachelor of Science Degree, University of Wisconsin School of Nuclear Engineering; licensed U. S. Atiny Reactor Operator; licensed Senior Reactor Operator, Point Beach Units 1 & 2; licensed Senior Reactor Operator La Crosse Boiling Water Reactor (LACBWR); served as Operations Engineer and Assistant Plant Superintendent prior to becoming Plant Superintendent - 14 years at LACBWR; member of the American Nuclear Society.

Operations Supervisor: U. S. Navy Nuclear Program; licensed Senior Reactor Operator, La Crosse Boiling Water Reactor; 24 years of experience as licensed Reactor Operator, Shift Supervisor and operations Supervisor at LACBWH.

Renctor J'ngineer: PhD in Nuclear Engineering, Iowa State University:

AEC er llowrhip in Nuclear Engineering; Senior Experimenter at Oak hidge Critical heility, Oak Hidge Nation,sl Laboratory; Instructor and Reactor Supervisor in Nuclear Engineerint, Iwa State University; Reactor Engineer nt LACBhTI, 20 yeare; inember of the American Nuclear Society.

Trhnical Surnort Engineer: D. S. Navy Nuclear Program; Bachelor's Degree in Businesa Administration, University of Wisconsin-Lacrosse; licensed Senior Reactor operabr, la Crosse Boiling Water Reactor; served as licensed llenctor Operator mid Senior Reactor Operator at LACBWR before becoming Technical. Support. Engineer - 15 yeara experience.

Rndint ion Protectdon_Enginrer: Master of Science Degree in Bionucleonics from Purdue University; Bacheler's Degrea in Radiological Environmental llenlth Purdue Univernity; served an IIcalth Physicist at Quad Cities Nuclear Power Station; 8 years experience as Radiation Protection Engineer at Le Crorse Boiling Water Renctor.

Director of Quality _Assurjuge: U. S. Navy Nuclear Program; 11 years experience with all aspects of Quality Assurance associnted with the maintenance, testing and operation of the LACBWR facility.

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Maintenance Sumrvisor: liigh School graduate with some post-high school vocational school education; Mechanic, Machinist / Welder and Maintenance Supervisor for the Dairylcud Power Cooperative - 34 years experience with Dairyland, 22 years experience at La Crosse Boiling Water Reactor.

Administrative Assistant: High School graduate; worked for Allis-Chalmers nuclear group as Secretary on the LACBWR project prior to employment by Dairyland; served as Stenographer and Secretary prior to becoming Administrative Assistant; member of Nuclear Records Management .

Association; 24 years experience at the La Crosse Boiling Water Reactor

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site.

lieulth & Safety Suter_v_ ism: High School graduate with 2 years of college chemistry: U. S. Navy Nuclear Program; worked as IIcalth Physics Technician and Radiation Protection Engineering Speclulist prior to becoming Health & Safety Supervisor; member of the North Central Chapter, llealth Physics Society; 11 years experience at LACBWR. l Shif t Supervisor. Crew A: GED qualified, 20 years Nuclear Navy experience, served as Operator Trainee and Shift Supervisor at LACBWR -

22 years experience at La Crosse Boiling Water Reacto .

Shif t Suiervisor, Crewj!: liigh School graduate wit! invy Nuclear background; served as licensed Reactor Operator and ticenced Senior Reactor Operator prior to becoming Shift Supervisor at LACBWR - 13 years  ;

experience at La Crosse Boiling Water Reactor.

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Shift Supervisor. Crew C: High School gr9duate with Navy Nuclear ,

backgrr.und; served as licensed Senior Reactor operator and Shift 4

Supervicor and Training Specialist at LACBWR - 18 yeurs experience at l La Crosse Boiling Water Reactor.

P Shif t Supervisor. Crew D: liigh School groduate with Navy Nuclear  ;

experience; served an licensed Reactor Operator arid licer. sed Senior

! Reacto;- Operator at IACBWR prior to becorsing Shi.f t supervisor - 17 y*:ars

! experience at La Crosse Dolling Water Rer.etor.

Sh& Supervisor, Relief & TraininL'Lrd Fire Protection _Supervireg: E i liigh School graduate with Navy Nuclear experience; sersed as licensed l Reactor Operator and Shif t Supervisor before becoming Relief Supervisc r i & Fire Protection Supervisor - 22 years experience at La Crosse Bolling

, Water Renctor.

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16. p. 8-4, Section 8.3.1

_A_dic_ COWrNT In accordance with Section 12.5, NURhW-0800, confim that your '>ealth physics procechives for performing bionssay durlng the SAFSNR period will conform to the recommendations of R\rgulatory Guide 8.26, "Application of Bionsse r for Fission and Activation Products, " or stdwit equivalent bloan.nay criteria.

DPC RESPONSE The bioassay program at LACBWR during the SAFSTOR period will be performed in accordance with the reconenendations of NRC Regulatory Guide 8.26. This bionssay program is described in an appropriate plant procedure. Page 8-4 of the Decoswiissioning Plan will be revised to I state:

l Bionssays will be perforised in accordance with the requirements of 10 CFR 20.103 and in confornance to the reconenendations of Regulatory Guide 8.26 "Application of Bioassay for Fission and Activation Products," and Regulatory Guide 8.32, "Criteria for Establishing a Tritime Bioassay Prograra."

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l 17. p. 8-9, Section 8.6 l

l Aw CwEM An estinate of the solid este to be generated during the SAF5M period should be provided so thnt ne can assess the mate ananagement larmcts.

Muis twtimte should include breakdowns by wate streau (dry active i waste, cartridge filters, filter sitxige, bewi resins, poonered resins, activated metals, specific decontamination solutions, etc.) and snente cisss (A,R,C and Greater-Than-Class-C). Hoe projected voluanea and activitiem by nuc11de ahouid be provided for each enaste sireen and wete class. Therse SAf5M projections should be campmred with operating mode newste generatiem data. Any changes to the procens contml program, mate classificatlan progran, the quality control progroan required under 10 CfR 20.311 and the trnnsportatlwo packaging progrian to uflect nw mste strennu or SAf5M modificntions should be identifled and informttwo provided for our revlw.

DPC RESPONSE Estimates of the solid wastes to he generated during the SAFSTOR period are found in Section 7.4 of the "Supplement to the Environmentr.1 Report for the Lacrosse Boiling Water Reactor (LACBWR) Post-Operating License Stage - SAFSTOR." These waste projections are corepared with operating modo waste generation data. These solid waste volumes and activitien may initially vary, but will be below operating mode average volumes and activities. It is scenewhat difficult to break down these solid wastes in teuns of DAW, cr.rtridge filters, filter sludges, bead resins, etc.,

i hut the majority of the wastes will he Class A unstable DAW and Clars A, B or C ntable dewatered whole bead derr.ineralizer resins. We anticipate that the average DAW volumes should not exceed 4.5 m3 per year rmd the average dewatered bead resin volumes should not exceed 3 m2 per year for the SAFSTOR period.

The Pt ocess Control Program (PCP), the quality control proPrn.n for solid r adionetive waste processing and the transportation packaging program should nat change significantly during the SAFSTOR period com:r.ensurate with changes in burial site requirements and federal regulations. The method of classifying wastes as required by 10 CFR 61 and 10 CFR 20.311 should not change. The isotopic bredkdown of waste stremas will change as will the total activities of generated solid radioactive wastes.

This is due principally to the lack of production and subsequent decay of the two primary radionuclides in waste, Fe-55 and Co-60. The radioactivity content of wastes should decrease from a historical operating average of 100 C1/ year to 20 Ci/ year during SAFSTOR. Periodic reclassification (isotopic analyses) of solid waste shall be performed in accordance with the PCP. Any changes to the PCP will be made in accordance with the requirements of Technical Specifications. At this tirne, we do not anticipate shipping irradiated componenu or greater than Class C wastes for disposal during the SAFSTOR period.

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19. AM _CQWN7' Describe the trentment and monitoring to be provided for effluent frca the refueling building ventilation exhaust, liquid waste storngo tankage vent exhaust, hot nochine shop vent exhaust, rmhmste trentment buiIding ventilation exhaust, the high-level solid radioactive waste storage vnulta, the icwlevel waste stornge building, the low-level waste handling building, and any othw pathway for the release of radianctive materfuls.

DPC RESPONSE Ventilation exhausts from the containment Building (CB), the Turbine Building (TB) and the Wasce Treatment Building (WTH) are routed to a plenum at the base of the 107m ventilation stack from where the exhaust air is discharged to the environment assisted by up to two 35,000-cfm rated stuck blowers.

The 107m ventilation stack air is monitored continuously by at least one fixed-filter particulate radiation monitor and one gaseous radiation monitor with a sample ptuup drawing air from the center of the stuck, isokinetically, through a nomins1 1" sample line. The monitors' indientions may be read in the control room or locally and have an alarm furetion.

1 i The CB is the refueling building in the 1.ACBWR facility, and its ventilation exhaust and treatment system is at. elescr' bed above anel on

p. 5-31 of the Deconanistioning Plan, The liquid wast e storage tanks vent to the T3 vene, obich subsequent h-nre open to the tunnel with its air flow to the 107m ventilntio:' atneh plenum. The ventilatior. fr.sm the hot machine shop, located in the

, turbine building, also exhaunts to the tunnel. The tunnel is monitored continuously by n fixed filter pn.-ticulate radiaticn monitor with a sample punp drawing air from the end of the tunnel prior to entry into the wtock plenum. This nonitor has a control room nnd local readout.

There is no filtrntion system on the turbine building venti btion exhaust.

The WTH v-ntilation exbnust includes the shielded solid radioactive waste storage vaults and the low-level waste handling / processing area.

This is described on p. 5-31 of the Decommissioning Plan. The WTH exhaust ventilution system is equipped with HEPA filtration system as describrd on p. 4-4 of t he Decommissioning Plnn.

The low-Ic. vel waste storage building is not equipped with a ventilation system. All waste stored in this building will normnlly be senled nnd the outer surfaces of the containers will be free of signifiennt removnble contaninntion. Any work involving the removal or repackaging of low-level radionetive waste in this buildin.: will require further nren controls und atmospheric monit oring.

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B. Technical Specifications

21. p. 1-1, Section 1.1 I

_W ME A local arew anp defining the unrestricted arens used for offalle done l cniculations for gnerous and 11guld effluents should be included in 15.

in mAlltlan, a site map ciently defining the rentrlcted aren pursvent to  !

10 Cnr 20.3(n)(i4) should be included. l j DPC HFSPONSE i

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A map which delineates the Effluent Helease Boundary (ERB), which by  :

.j definition is the DPC property line within the 1,109 ft. (338 in) radius t (old) Exclusion Area, is found on Figure 3.3 of the Decommeissioning  !

! Plan. This figure is also found in the Offsite Dose Calculation Manual l

(ODCM) and the Emergency Plan, which are used for offsite done ,

i calculations for gaseous and/or liquid effluents. It is not necessary [

to include this map in the Technical Specifications. 7 l A site map with the current Radiological Restricted Area is shown on Figure 3.4 of the Decommissioning Plan. By definition, on page 2-3 of ,

i the proposed Technical Specifications, the Restricted Area "shall be eny ,

. area within the (1100 ft. or 338m) Exclusion Area, access to which is i

controlled by the licensee for purposes of protection of individuals l

/ from exposure to ionizing radiation und radioactive mtorials. The  :

! Restricted Area may therefore vary in size, as long as it r . mains willdn l j the Effluent Helease Poundary. It is not necessary to inci'ade this innp

in the Technical Specifications, j i c  ;

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34. p. 6-3. Section 6.5.1 M WR-The propened canvasilievo includes all IACBMl? Depnrtwnt Supervisors, i Engineers, Shift Supervisors and mrn'gement personnel. We consider the l armhership should be fixed and considered in conjunction wit): the quoruar i requirements such that the quornar is a mjority of the ctantittee  ;

BrMOcfW.  ;

DPC RESPONSJ

, i The existing Technical Specifientions for the I.acrosse Boiling Water ,

Reactor (LACBWR) were submitted and accepted in recognition of the need ,

to have Operations personnel involved in the Operations Review Convoittee (ORC). The ORC Charter for LACBWR requires that the staff person (s),

whose expertise would be required for a specific topic being discussed, i l be in attendance at that ORC meeting. There are only thirteen (13) I designated ORC members, of whom four are on rotating shif t. In order to l

) maintain the desired flexibility for ORC membership and ineeting attend- l

! ance, the Technical Specifientions, as submitted, should be approved, t 4

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35. p. 6-4, Section 6.5.1.6

' AfiiC CU NINT i i

Me suggest expanding the C)perations Review Canarittee responsibilitics to include review of the waste menagement quality control prvgran required  ;

urukr 10 CIR Part 20.311, eunt the trnusportation packaging progran. l l DPC RESPONSE l

An additional responsibility of the Operations Review Coassittee will be  !

included under Section 6.5.1.6 of Technical Specifications, as follows:  !

k. Review the waste managerment process control program and the transportation packaging program. I b

i i l 36. p. 6-5. Section 6.5.2.1  !

4 NM: CON (NT l We suggest adding unste annagceent as a review function ot* the Safety j 1

Review Conwittee. [

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DPC RESPONSE f 1 i 4

- An additional function of the Safety Review Coma:ittee will bn included  :

under Section 6.5.2.1 of Technical Specifications, as follows: t i

i 1. Waste management  ;

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. t C. Supplement to Environmental __Heport  :

40. p. 4, Section 5.2 MM

- Provido an cetlante of the snumber of curlayers tv.9ultni for the SAisitW deccaurissioning time period. Provide a brenkdoom of the eunplayres

requirnt by permanent and contractor workers. If this trumber la not ,

expected to be relatively stable, give estimste of cJmnges anticipnted, r DPC Resp 0NSE

The nund>cr of employees estimated for the SAFSTOR decomenissioning time i i period was included ic, Figure G.1 of the I.ACBWR Decomreissioning Plan.

l It indicates 3 health and safety technicians, at least 3 mechanical maintenance persons, 2 instrument technicians, 2 electricians, 5 shift L i

supervisors, G operators, 3 engineers, 1.5 clerical, I administrative I assistant, 3 department supervisors, and 1 plant superintendent. The  !

nued)er of employees indicated is expected to be stable throughout the  !

i SAFSTOR period; therefore, no changes were anticipated or provided in l 1 the original submittal. Dairyland does not intend to utilize contract [

l employees in staffing theoe positions, t t  ;

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42. p. 14, Section 7.3'

1. E' NET ,

You oisted ths i after LACM uns permncutly shut skwn in Apri1, J.WW, i merked changes in the magnitude and connrosition of radioactive inseous j effitmots were caserved, j (n) Ikwcrlhe crav>onititwo and quantitles of rmflonctive gnsernas effluent  ;

i expected during the sal 5W period of ekconmissievring.  ;

L i (b) Dencrlhe ytnsr plan to recallbriste 1.4CM prvcess arni effitn'nt t radiatteur mwritors in accordance with the energy levels of the (

l rmilanuclides expected in liquid aruf guscoun effluents during the >

l sal 5M perlod.

OPC HRSPONSR 1

i The first sentence of th,e NHC Comenent states a LACIMH shutdown date of d

April, 198G. The year should be corrected to 1987.

l As indicated in the Supplement to the Environtaental Report, on p. 14,

) "there are essentially no noble gas (Kr. Xe, Ar) nor radiciodine (I-131, 1 1-133) releases, since they are no longer being produced by the fission  !

j process.... The particulate releases in gaseous effluents have t i decreased by a factor of nhout 60-100 times since shutdown. The trititna [

! releases in ganeous offluents have significantly decreased." A table of f J projected estimated gaseous releanes durlog SAFSTOR would be illustrated i

). as follcws: j L

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.__^ 9133vjtyjcuries)  :  !

kndionuelide '

: Annual Avernge _: [

_ _C91rlety , ,

1988 _ 19_89  := 1990-2010  ; j 7

_,.Kr;85  : 92001  : 0 001  : 6 E-4  :  ;

:  :  : l

!._.0ther_j M lp pntt3_,,  ! .,__,jip' (__ ND  : ND  :

,_JI;3 ,,,

! lL000  : .l.500  : 1,000 _

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_ E131., 133  : ND. ND  : ND  :

:  :  : i  ;

! {- 12.9 _

_fD

! ND  ! ND -l  !

Particulntes l  : -

LTt zt.)_3_itayM __, -- : 2 E;5 : U i-fa !__ __ _

4 E-6 i [

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• ND = None Detectable  !

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By the end of first quarter 1989, all noble gas monitors which employ the use of beta scintillation or cht detectors will be recalibrated to a known standard of Kr-85, which is the principal noble gas radionuclide remaining in irradiated fuel assemblies. All particulate-type fixed filter monitors which einploy the u.e of beta scintillation or .

end-window GM_ detectors will be recalibrated to a standard of Cs-137, which has an E heta, which represents the approximate E beta of _

radionuclides that may be detected in gaseous effluents. The current E L beta for the gaseous effluent is approximately 0.145 MeV and should increase to approximately 0.2 MeV during the SAFSTOR period, due to decay of shorter-lived nuclides.

In the case of the liquid effluents, the monitors are recalibrated with a mixture of ganana emitting radionuclides which are currently identified in liquid waste streams. This includes Co-60, Cs-137, Mn-54, Cs-134, Ag-110m, Ce-144 and 2n-GS. Thin has been accomplished and will be performed every 18 months, as required by Technical Specifications.

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43. p. 17, Section 7.4 NIC CO MAT The atatcd voituees and activitiew uptwar ta be low cormidering statements in the Decomeissioning Plan that some decontamination and dismust1cmant any Iahe pince daving ihe SMSmR period. In addltion, ,

the Decoeurinsioning Pinn niso states Ihat some activnted metnia muy be shipped for disposal. If so, the act tvitles in Tabic 7-9 muy be substantially understated.

noe busca for the valuca pnwentevi in Table 7-9 should niso be discussed.

DpC RESPONSR The footnote (1) to Table 7-9 of the "Supplement to the Environmental Report" stated that the waste volumes for the period 1990-2010 "assumes periodic shipments of contruninated and/or irradiated components no longer required for SAFSTOR maintenance and surveillance." At this time, we do not anticipate shipping highly irradirited components or greater than Class C wastes for disposal during the SAFSTOR period.

The values for projected solid radioactive waste volumes and activitiet.

are based upon analyses of the average operational waste volumes and activitles, and the future non-operatinnal waste volumes, considering future filter /demineralizer usage and dry active waste generation rates.

The reduction of activities are primarily due to the anticipated 1 reduction in volumes, the lack of production of activation / fission radionuclides, tnd the deeny of key waste radionuclides, principally l Ma-54, Cc-144, Fe-55 and Co-60, during the SAFSTOR period. We expect to genernte an annual average of 4.5 m' DAW and 3.0 m 3 spent demineralizer e resins during the longer term SAFSTOR period. We expect to have an annual average of 15-20 Curies in solid radioactive waste during this  :

! period.

In the case of contaminated components, the reductions in average volumes may be accomplished, as indicated in Section 7.3.2 of the  ;

Decounissioning Plan, by decontamination to the point that components '

. contain no detectable radioactive material, prfor to transfer to an unlicensed user (scrap) or for disposal as commercial solid waste. This was performed in 1987, when 3 slightly contaminated heat exchangers were sent to a contractor for decontaminetion, and subsequently released as ,

non-radioact ive scrap inctal. These heat exchangers had a total volume L of about 1200 ft2 The total radioactive waste volume generated, af ter complete decontamination of these heat exchangers, was under 250 f t2, l for an effective volume reduction factor of 4.8. The effective cost reduction factor for this project was about 1.75.

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44. p. 17, Section 7.4 NW CtWNrNT Secticwo 7.4 describes solid nnkmste processing and shipments.

(a) Provide the LACRMt Process Control Progran to be used charing the SM51tW period including (1) omste classification methcxhr in accordance with 10 :'IR 61.55 and (2) neste characteristics in accorchance with 10 CJR 61.56.

(b) Deacribe the projected low level radioactive unnte shipments from LACRMV charing SM51tW in teran of type of amnte (solidified or deemtered spent resin, dry rmflonctive waste, solidified filter alukes, solidified decantaminaticut soste, etc.) arnt its rmflonctivity content, ppC RESP 0NSE (a) The I.ACBWR Process Control Program which is being used currently and will be used during the SATSTOR period is implemented by plant procedures. This program describes the various solid waste streams, pric2ipally low level dry-active waste-unstable Class A, spent demineralizer resins-stable Class B or C, and contaminated hardware and components-stable Class A, B or C. The procedures identify the methods used to process these wastes into packages suitable to meet the requirements for shipping and disposal in accordance with applicable transportation and burial site regulations.

Solid radioactive waste material is classified in accordance with 10 CFR 61.55, by periodically sending representativo sample aliquots of the various waste streams to a contractor analytical laboratory for analysis of concentrations of radionuclides listed

.n 10 CFR 61.55 Tables 1 and 2. In addition, gamma emitting rmlionuclides such as Co-GO and Cs-137 are quantified. Using the sum of fractions rule described in 10 CFR 61.55 (a)(7) and the radionuclido concentrntions listed in 10 CFR 61.55 Tables 1 and 2, if applicable, specific waste stream classifications are determined.

Irrespective of determined classifications, the criterion of 10 CFR 61.5G is used to process and package solid radioactive waste to facilitate disposal site handling and provide protection of the health and safety of site personnel. For example, dry active waste is packaged in DOT-Spec 17H steel drums or DOT-Spec 7A wooden boxes und not in fiberboard boxes. Pyrophoric, flawaable or explosive materials are not packaged as solid waste. Free standing liquids are maintained below 1% of the total volume of dewatered spent resins in high integrity polyethylene containers. Containers that provide structural stability for waste disposal are used na part of the Process control Program in accordance with 10 CFR 61.56(b).

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(b) See response to question No. 17.

45. p. 25, Section 9.1 Afic CtWE#r  ;

r A'valsmte potesstini accideratel relense of the INSW csoling meter aruf of  ;

liquide from the moet critical .adioactive waste storage tank to the grounawter arnt surfew unter.

DPC RESPONSE The FESW cooling water system is located entirely in the containment building. In the event of a non-controlled leak from the FESW system, the water would accumulate in two 6000-gallon Retention Tanks located in _

the Containment Building basement. In the event that these two tanks l leaked or overflowed, the FESW water would accumulate in the containment (

Building basement and sub-basement areas. This water would be isolated i from the environment, and there would be no potential for subsequent leakage into ground water nor into surface water, except by a controlled batch discharge release to the waters of the Mississippi River via the ,

liquid waste discharge system. Therefore, there is no potential accidental release of FESW water to ground water or surface water.

t The Retention (Waste) Tanks discussed above are considered to be the  ;

nost critical radioactive waste storage tanks during the SAFSTOR period.

47. p. G-15, Sections G.9.4 met <

Statewnnts in these sectiam invly that the Mal <m flooding system arv  ;

availabic for the electrical equiswent room and the arcord storage roon i but the Mnicm system in the electrient equijment room will not he needed and has been dropmd free M. Please provide justification for deleting I this systew since amt of the Control hbcw circuits pass thru the  ?

electricn! equipment roon. l r

,DJ'c RfS!'O@E j The Halon flooding system in the electrien1 equipment room will remain [

operable and the requirements for its operablity will be added to the ,

SAFS'N)H Technical Specifications.

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49. p. 6-1, Section 6.2.1 ANC COwWM h6 organisatiem charts arv prvvidal in the prpponed TS. Dis la acceptable providal the charts are part of the alpproved Quality Aneurance Plan (Q4P) natch is updatal and nuhmitted annunily for RWlon III review. De lent GtP, subeltted Decraber 21,1987, and anpdated Aberch 28,19FG, referred to but did not include the LACBMt organisation chart for the SM51tw snode an sheens in figure 6.1 of the Decesarissicaning Plan. Nin chart should be included in the next gip suharittal or added to TS along with the Div organisation chart.

DEC_jtESPONSE The organization chart for the SAFSTOR period was provided in the Decoussissioning Plan. We will add it to the Quality Assurance Program Description scheduled for submittal in March 1989, s

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