ML20352A234

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Response to Request for Additional Information Re Revised Final Status Survey Final Reports
ML20352A234
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 11/02/2020
From: Gerard van Noordennen
La CrosseSolutions
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML20356A041 List:
References
LC-2020-0023
Download: ML20352A234 (37)
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LACROSSESOLUTIONS November 2, 2020 LC-2020-0023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 La Crosse Boiling Water Reactor Facility Operating License No. DPR-45 NRC Docket Nos. 50-409 and 72-046

Subject:

Response to Request for Additional Information Regarding the LaCrosseSolutions Final Status Survey Final Reports

References:

1) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "Final Status Survey Final Report - Phase 1," dated September 11, 2019
2) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "Final Status Survey Final Report - Phase 2," dated December 13, 2019
3) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "Final Status Survey Final Report - Phase 3," dated January 28, 2020
4) Bruce A. Watson, U.S. Nuclear Regulatory Commission, Letter to John Sauger, EnergySolutions, "La Crosse Boiling Water Reactor- Request for Additional Information Regarding the Lacrosse Solutions Final Status Survey Report and Supporting Information," dated August 19, 2020 LaCrosseSolutions submitted the Final Status Survey (FSS) Final Reports for Phases 1 through 3, for NRC review, as documented in References 1, 2, and 3. The NRC staff reviewed the FSS Final Reports for Phases 1 through 3 and determined that additional information was required to complete its review. LaCrosseSolutions received a Request for Additional Information (RAI) from the staff on August 19, 2020 (Reference 4).

The purpose of this letter is to submit a detailed response to the RAI; the response is provided in . As a result of the RAI, the FSS Final Reports for Phases 2 and 3 were revised along with thirty-one related release records. In addition, a document providing Insignificant Contributor (IC) dose calculations was developed to support an RAI response. The revised documents, as well as the IC dose calculations and relevant technical support documents, are provided electronically on the enclosed CD. Documents provided electronically include the following:

S4601 State Highway 35, Genoa, WI 54632

LaCrosseSolutions LC-2020-0023 Page 2 of 2 Documents Provided on Enclosed CD Release Record- Survey Unit B 1-010-001 Release Record- Survey Unit L 1-SUB-TDS Release Record- Survey Unit Bl-010-004 Release Record- Survey Unit L2-011-101 Release Record- Survey Unit B2-010-101 Release Record- Survey Unit L2-0l 1-104 Release Record- Survey Unit B2-010-102 Release Record- Survey Unit Sl-011-102 Release Record- Survey Unit B2-010-103 Release Record- Survey Unit S2-011-101 A Release Record- Survey Unit B3-012-101 Release Record- Survey Unit S2-011-101 B Release Record- Survey Unit B3-012-102 Release Record- Survey Unit S2-011-103 A Release Record- Survey Unit B3-012-103 Release Record- Survey Unit S2-011-103 B Release Record- Survey Unit B3-012-104 Release Record- Survey Unit S2-011-103 Release Record- Survey Unit B3-012-109 Release Record- Survey Unit S3-012-102 A Release Record- Survey Unit Ll-010-101 C Release Record- Survey Unit S3-012-102 B Release Record- Survey Unit Ll-010-101 Release Record- Survey Unit S3-012-109 B Release Record- Survey Unit Ll-010-104 FSSRPhase 2 Release Record- Survey Unit Ll-010-105 FSSRPhase 3 Release Record- Survey Unit Ll-010-106 LACBWR IC Dose Calculations Release Record- Survey Unit Ll-010-107 LC-RP-PR-060 Release Record- Survey Unit Ll-SUB-CDR LC-FS-PR-018 Release Record- Survey Unit Ll-SUB-TDS-A LC-FS-TSD-005 Release Record- Survey Unit Ll-SUB-TDS-B LC-FS-TSD-003 There are no regulatory commitments made in this submittal. If you should have any questions regarding this submittal, please contact me at (860) 462-9707.

Respectfully, Gerard P. Van N oordennen Nov 2 2020 5:42 PM cosign Gerard van N oordennen Senior Vice President Regulatory Affairs Attachments:

Attachment 1: Response to Request for Additional Information Regarding the LaCrosseSolutions Final Status Survey Final Reports Attachment 2: Preflight Report for Enclosure to LC-2020-0023

Enclosure:

CD Containing Revised Final Status Survey Final Reports and Related Release Records, and the LACBWR IC Dose Calculations as Referenced in the Response to the Request for Additional Information cc: Marlayna Doell, 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 Paul Schmidt, Manager President and CEO Radiation Protection Section EnergySolutions Bureau of Environmental and Occupational 299 South Main Street, Suite 1700 Health Division of Public Health Salt Lake City, UT 84111 Wisconsin Department of Health Services P.O. Box 2659 John Sauger Madison, WI 53701-2659 President and Chief Nuclear Officer ReactorD&D Barbara Nick President and CEO EnergySolutions Dairyland Power Cooperative 121 W. Trade Street, Suite 2700 3200 East Avenue South Charlotte, NC 28202 La Crosse, WI 54602-0817 Joseph Nowak Cheryl Olson, ISFSI Manager Project Manager La Crosse Boiling Water Reactor LaCrosseSolutions Dairyland Power Cooperative S4601 State Highway 35 S4601 State Highway 35 Genoa, WI 54632-8846 P.O. Box 817 Genoa, WI 54632-8846 Gerard van Noordennen Senior Vice President Lane Peters Regulatory Affairs La Crosse Boiling Water Reactor EnergySolutions Dairyland Power Cooperative 121 W. Trade Street, Suite 2700 S4601 State Highway 35 Charlotte, NC 28202 Genoa, WI 54632-8846 Russ Workman Thomas Zaremba General Counsel Wheeler, Van Sickle and Anderson, S.C.

EnergySolutions 44 East Mifflin Street, Suite 1000 299 South Main Street, Suite 1700 Madison, WI 53703 Salt Lake City, UT 84111 Andrew J. Parrish Jerome Pedretti, Clerk Wheeler, Van Sickle & Anderson, S.C.

Town of Genoa 44 E. Mifflin Street, Suite 1000 E860 Mundsack Road Madison, WI 53703 Genoa, WI 54632 John E. Matthews Jeffery Kitsembel Morgan, Lewis & Bockius LLP Division of Energy Regulation 1111 Pennsylvania Avenue, Wisconsin Public Service Commission NW Washington, DC 20004 P.O. Box 7854 Madison, WI 53707-7854

La CrosseSolutions LS-2020-0023 Attachment 1 La Crosse Boiling Water Reactor Response to Request for Additional Information Regarding the LaCrosseSolutions Final Status Survey Final Reports

LaCrosseSolutions LC-2020-0023 Response to Request for Additional Information Regarding the LaCrosseSolutions Final Status Survey Final Reports RAI-la - Path Forward: Section 5.6.4.6 of the LACBWR LTP states that areas exceeding given investigation levels will be "addressed by further biased surveys and sampling as necessary" according to the investigation levels in Table 5-16, "FSS Investigation Levels." The licensee should provide additional details regarding the process that was followed for determining when further biased surveys and sampling were deemed necessary.

RAI-la - LaCrosseSolutions Response: LaCrosseSolutions provides the following additional details regarding the process that was followed for determining when further biased surveys and sampling were deemed necessary.

LaCrosseSolutions perfonned an extent of condition review with regard to investigations for all survey units. In all survey units where an investigation was warranted, an investigation occurred.

Three survey units (Ll-SUB-TDS, Ll-010-101 C, and Ll-SUB-CDR), though, had scanning alarm set points that were much higher than the alann set points established for FSS performed in other survey units subsequent to these three survey units. While the investigation protocols outlined in Section 5.6.4.6 of the LTP were followed with the investigation levels established in these three survey units, a comparison of the scan data from these survey units to the correct investigation levels results in several locations where scan alarms would have occurred and, in tum, would have triggered investigations. No further action was deemed necessary for these survey units because all the soil sample data, both systematic and judgmental, resulted in activities at small fractions of the OpDCGLs. Based on the distribution of the systematic and judgmental samples collected within these survey units, the probability of discovering an area of soil with elevated activity is very low, and LaCrosseSolutions is confident that had additional investigational samples been collected, the data would be comparable to the existing data (i.e.,

well below the OpDCGLs). Additionally, post-remediation results in survey unit Ll-010-101 C reveal activity levels consistent with the subsequent FSS activity levels. Three (3) soil samples were collected at the edges of the remediated area and analyzed using the on-site gamma spectroscopy system. Cs-13 7 was detected at concentrations greater than MDC in all three of the samples, with a maximum concentration of 2.30E-01 pCi/g. Co-60 was detected at concentrations above MDC in two (2) of the samples, with a maximum concentration of 2.71E-02 pCi/g. The results of these samples are well below 50% of the OpDCGLs.

Regarding the discussion of reclassification criteria in the RAI, the 1% OpDCGL reclassification criterion for Class 3 survey units in LTP Table 5-17 is only applicable if an investigation was initiated and the results of the investigation confirm residual radioactivity in excess of 50% of the OpDCGL. It is not a criterion for which all data are compared to.

LTP Section 5.6.4.6.1, Remediation, Reclassification, and Resurvey, states, "If an individual survey measurement in a Class 3 survey unit exceeds 50 percent of the OpDCGL, then the survey unit, or a portion of a survey unit, will be investigated. If the investigation confirms residual radioactivity in excess of 50 percent of the OpDCGL, the survey unit, or the impacted portion of the survey unit will be reclassified to a Class 1 or a Class 2 survey unit and the survey will be re-designed and re-performed as discussed above for Class 1 or Class 2."

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LaCrosseSolutions LC-2020-0023 LTP Section 5.6.4.6.1 also states, "The DQO process will be used to evaluate the remediation, reclassification and/or resurvey actions to be taken if an investigation level is exceeded. Based upon the failure of the statistical test or the results of an investigation, Table 5-17 presents actions that will be required."

Actions in Table 5-17 are required when the statistical test fails or when an investigation confirms residual radioactivity in excess of 50 percent of the OpDCGL. In the balance of Class 3 survey units, the Sign Test was passed; therefore, the 1% OpDCGL criteria stated in Table 5-17 was not applicable. In summary, in all instances when the investigation level was triggered for a Class 3 survey unit (50 percent of the OpDCGL or an OpSOF greater than 0.5),

LaCrosseSolutions remediated, reclassified, or resurveyed using Table 5-17. If the investigation verified levels between 1% and 50% of the OpDCGL, then the survey unit, or a portion of the survey unit, would have been reclassified as a Class 2 survey unit. If the investigation verified levels that were greater than 50% of the OpDCGL, then the survey unit, or a portion of the survey unit, would have been reclassified as Class 1.

RAI-lb - Path Forward: For relevant survey units, provide a reasonably bounding evaluation of the potential dose impacts of areas that should have been investigated per Section 5.6.4.6 of the LACBWR LTP, but were not investigated. When assessing the dose impacts, take into consideration the potential misclassification of survey units or portions of survey units. The response should include a review of all impacted survey units and should not be limited to the survey units that are discussed as examples in this RAI.

RAI-lb - LaCrosseSolutions Response: An extent of condition review for all survey units was performed (see response to RAI-la). Three survey units (Ll-SUB-TDS, Ll-010-101 C, and Ll-SUB-CDR) had scanning alarm set points that were much higher than the alarm set points established for FSS performed in other survey units subsequent to these three survey units.

Comparing the scan data from these survey units to the correct investigation levels results in several locations where scan alarms would have occurred and, in tum, would have triggered investigations. Given the soil sample results from FSS and post remediation, all below 50% of the OpDCGL, a revision to the dose assignments is not warranted.

RAI-lc - Path Forward: For the Turbine Building, Sump, and Pit Diesel Excavation (Survey Unit Ll-SUB-TDS), provide a survey map that shows the scan locations in comparison with the judgmental sample locations for the survey unit.

RAI-lc - LaCrosseSolutions Response: During the review of Table 7-1 of the release record for survey unit Ll-SUB-TDS, discrepancies were identified in which incorrect scan grids had scanning alarms. The release record for survey unit L 1-SUB-TDS has been revised to include the following changes:

  • Table 7-1 was revised to reflect the correct scan grids that had scanning alarms.
  • Figures 16-1 and 16-2 were replaced with figures that have the scan grids overlaid onto the systematic and judgmental sample locations.

The revised release record is included in this response.

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LaCrosseSolutions LC-2020-0023 RAI-ld- Path Forward: For the WTB Excavation (Survey Unit Ll-010-101 C) and RPGPA Excavation (Survey Unit Ll-SUB-TDS B) Geoprobe samples, the licensee should discuss why they are confident that the Geoprobe samples represent the end state of the bottom of the excavations and can be relied on as part of the release records.

This discussion should include the following information, as a minimum:

  • Discuss how the depth of the Geoprobe sample was determined, including any visual cues used to verify that the top of the excavation was indeed sampled as opposed to the fill or beneath the excavation, etc.
  • Provide additional details on the sampling approach for the 3-foot stratums obtained using the Geoprobe method in the WTB Excavation and RPGPA survey units. These additional details should describe whether the entire 3-foot stratum length comprised the 1-liter sample, or a portion of soil from each stratum was selected and analyzed. The details should also state whether the 3-foot stratum was mixed before being analyzed.
  • Provide additional basis for why the I-liter sample is representative of the 6-inch layer that would have been directly below the interface of natural soil and backfill, and that the sample for this targeted zone is not diluted by additional material (natural sediment or backfill) from the 3-foot lengths of core. In addition, provide a discussion of any considerations that were used to ensure that the 6-inch layer was not inadvertently split between the bottom two core lengths, if the sample results were not mixed before analysis.

RAI-ld - LaCrosseSolutions Response: The depths of the Geoprobe sampling events varied between the two survey units. LI-010-lOI C was backfilled with G3 soil, which was much darker than the soil at the bottom of the excavation (native soil); a difference in soil is noticeable.

Sampling was performed until the excavation/backfill interface was encountered, with the excavation soils collected for a sample. For LI-SUB-TDS B, the excavation and backfill interface could not be determined. As such, one-meter samples were collected to a total depth of four meters. LaCrosseSolutions is confident the GeoProbe samples capture the bottom of the excavation, because 4 meters of material was collected, and the lowest elevation soil strata did not often contain plant-related activity above MDC. The data used to demonstrate compliance was the maximum activity from the 4 I-meter samples collected at each location.

At each sampling location, the entire three-foot stratum was mixed to comprise the sample.

Additional sample borings were often needed at locations to obtain sufficient volume for analyses. These borings were also mixed with the original sample prior to analyses.

The dose modeling for soils at LACBWR assumed a one-meter depth as detailed in section 6.8.2 of the L TP. As such, separation of the six-inch layer directly below the backfill was not necessary since it falls within the one-meter thick geometry factored in the dose model.

RAI-le - Path Forward: For the WGTV Basement (Survey Unit B1-010-004), the licensee should provide additional information about the rain event to demonstrate that the rain event did not affect the radiological status of the survey unit, since the systematic FSS samples were taken prior to the rain event and were not repeated after the rain event. The licensee should provide the scan data for the survey unit both pre-rain event and post-rain event.

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LaCrosseSolutions LC-2020-0023 RAI-le - LaCrosseSolutions Response: The WGTV basement was protected by Best Management Practices (silt fence and waddles) for surface water drainage. Based on subsurface soil data from continuing characterization, the soil area around the WGTV did not require remediation. LaCrosseSolutions evaluated post-rain event scan data, post-rain event water and sediment data, and the subsurface soil data from continuing characterization. Based on these results, there is no indication that the as-left radiological condition of the WGTV basement changed as a result of the rain event. LaCrosseSolutions revised the release record for survey unit B 1-010-004 to provide the pre and post-rain event scan data, as well as the post-rain event water and sediment gamma spectroscopy reports. The revised release record is included in this response.

RAI-lf- Path Forward: For the LACBWR Crib House (Survey Unit B2-010-101), the licensee should indicate whether the three static measurements discussed were investigation measurements.

RAI-lf- LaCrosseSolutions Response: The three static measurements in question (B2-010-101-FSRC-A07-BD, B2-010-101-FSRC-Al0-BD, and B2-010-101-FSWM-B01-BD) were not considered investigation measurements due to the nature of the survey instructions provided in the sample plan, which consists of scanning a grid in serpentine fashion and collecting a one-minute static measurement at the location of highest scan indication. In this sense, the three systematic static measurements, which did not produce alarms, were adequate to ensure that no further action was needed. As a result, investigations (i.e., additional measurements) were not conducted.

The release record for survey unit B2-010-101 was revised to include a discussion on why investigations were not conducted for these three survey locations. The revised release record is included in this response.

RAI-lg- Path Forward: For the Stack, Pipe Tunnel, and RPGPA Excavation (Survey Unit Ll-SUB-CDR), the licensee should review why the six investigational samples were not labeled correctly and the coordinates not collected. The licensee should also include a discussion of the nature of the Sump #1 and Sump #2 samples and the results of the analysis.

RAI-lg- LaCrosseSolutions Response: The six investigational samples were taken during an NRC inspection and were labeled in the order collected. The samples were not labeled in accordance with procedure, however the field notes indicate that samples NRC #4 through NRC

  1. 9 were collected in response to scan alarms in survey unit Ll-SUB-CDR. Samples Sump Area #1 and Sump Area #2 were taken from the RPGPA, which was excluded from survey unit Ll-SUB-CDR; therefore, the data was not included with the FSS for survey unit Ll-SUB-CDR.

Additionally, because both sumps were removed during remediation, neither of the samples were utilized for FSS. The RPGPA where samples Sump Area #1 and Sump Area #2 originated became survey unit Ll-SUB-TDS B. The release record for survey unit Ll-SUB-TDS B was revised to include a discussion and the results of on-site and off-site analyses of the Sump Area #1 and Sump Area #2 samples. The revised release record is included in this response.

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LaCrosseSolutions LC-2020-0023 RAI-lh- Path Forward: For the RPGPA Excavation (Survey Unit Ll-SUB-TDS B), clarify how the three samples that were closest to systematic sample location Ll-SUB-TDS-FSGS-B04-SB were evaluated during the investigation phase of the survey. Please explain whether the result of the judgmental boring sample (B36) taken directly adjacent to this elevated systematic sample location was expected, given the different Cs-13 7 concentrations ( 1.2 pCi/g for B3 6 compared to 24.4 pCi/g for Ll-SUB-TDS-FSGS-B04-SB). Include any relevant details regarding the depths from which the two samples were collected, and the size(s) of the Geoprobe used in the survey.

RAI-lh - LaCrosseSolutions Response: As shown in the figure in Attachment 1 of the release record, the area sample B04 was collected was immediately outside where the trench box was located. It is also located where a solid side of the trench box was present. When excavating the interior of the trench box, the interior (middle) portion of the box is removed, and the box settles into the ground further. This pushes sand and soils to and along the sides of the box. When the trench box was removed, materials (sand) on the sides of the trench box sloughed into the area.

The area was also underwater due to the river level. As such, no remediation was possible, and it is reasonable to assume that the area would vary in contamination levels. The Cs-13 7 concentrations of adjacent samples (B32 at 6.05E+00 pCi/g, B33 at 1.1 lE+0l pCi/g, B34 at 5.21E-01 pCi/g, and B35 at 7.92E-02 pCi/g), are all below the OpDCGL, and are indicative of the variation in activity outside the trench box because full remediation was not possible. The area was also sampled at multiple locations, resulting in a high sample density for the area. Both samples (B04 and B36) were at the same stratum of 624 feet to 627 feet. The GeoProbe performing the sampling utilized 1-1.5" sampling tubes.

RAI-li- Path Forward: For the Eastern Portion of the Turbine Building, Sump, Pit, and Diesel Excavation (Survey Unit L 1-SUB-TDS A), the licensee should provide a map of the scan locations and a more detailed explanation of the investigations, remediation, and resurvey of the area. The information should distinguish between the scans and sampling that were conducted prior to remediation, versus those conducted post-remediation.

The details should include all the scan and soil sample results that were taken after FSS activities commenced (June 26, 2019), even those that were discarded due to the subsequent remediation.

The response should also explain why the result for judgmental sample A20 was discarded, as it appears to be outside the blue dotted line indicating the excavated/ remediated area in Figure 16-1 of the release record. If the result for sample A20 was intentionally discarded, indicate why and whether it was used as a judgmental sample result in an adjacent survey unit and indicate which survey unit. The licensee should also revise the figure in Attachment 1 of the release record to show that sample A20 was outside of the survey unit boundary.

Finally, the licensee should perform an analysis that demonstrates the survey design and DQOs for survey unit Ll-SUB-TDS A are still valid, and that the proper resurvey FSS was conducted given that remediation was necessary in this area.

RAI-li - LaCrosseSolutions Response: LaCrosseSolutions has revised Attachment 1 of the release record for L 1-SUB-TDS A to include a map showing the 84 scan lanes. The release record was updated to provide a more detailed explanation of the investigations, remediation, and resurvey of the area and will provide a clear distinction between the scans and sampling that were conducted prior to remediation, versus those conducted post-remediation.

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LaCrosseSolutions LC-2020-0023 Sample Ll-SUB-TDS-FJGS-A20-SB was inadvertently excluded from the data set. In reality, three samples (Ll-SUB-TDS-FJGS-A16-SB, Ll-SUB-TDS-FJGS-A21-SB, and Ll-SUB-TDS-FJGS-A22-SB), which were collected in the remediation area prior to remediation, were excluded from the final data set as they no longer represented the final configuration of the survey unit. The release record also included an analysis that demonstrates the survey design and DQOs are still valid, and that the proper resurvey FSS was conducted given that remediation was necessary. The revised release record is included in this response.

RAI-2a - Path Forward: Provide additional details supporting the licensee's confidence that the FSS sampled the appropriate interface between the bottom of the RPGP A excavation and the backfill.

RAI-2a - LaCrosseSolutions Response: See LaCrosseSolutions' response to RAI-ld.

RAI-2b - Path Forward: Include a discussion of the timing of the demolition and subsequent backfill of the Reactor Building, and indicate when the source related to shine from the Reactor Building was eliminated in comparison to the timing for the RASS and FSS activities.

RAI-2b - LaCrosseSolutions Response: The source related to shine was materials located above and below grade within the Reactor Building. Building systems, components and interior structure were removed from the 660' elevation and above from December 2017 to February 2018. Building systems, components and interior structure were removed from below the 660' elevation from February 2018 to August 2018. As materials were removed from the Reactor Building, the containment liner started to float due to elevated river levels. The liner was stabilized, and a Contamination Verification Survey was performed on the upper portion of it.

The upper portion of the steel was cut and removed, followed by removal of the materials in the base and the base of containment itself. In 2017 and early 2018, when RASS scan surveys were performed in the RPGPA area, the source term would be present since the interior of the Reactor Building was being stripped out. The source term was removed prior to the FSS of the RPGP A area in 2019.

RAI-2c - Path Forward: Indicate the model of the probe that was used for the RPGPA RASS, in addition to the Ludlum Model 2221 Scaler-Ratemeter. Discuss the soil concentrations the licensee would expect to see from a result of 55,000-60,000 cpm for this type of detector, and whether the activity concentrations of 5 pCi/g of Cs-137 and 0.147 pCi/g of Co-60 in the soil samples were expected results. In addition, the licensee should take into account the geometry of the 15-foot trench when comparing the RASS scan data to the sample results, as well as in the discussion of shine from the LACBWR Reactor Building.

RAI-2c - LaCrosseSolutions Response: The detector used for the surveys was a Ludlum 44-10 2" x 2" NaI detector. Utilizing RS-TD-313196-006 "Ludlum Model 44-10 Detector Sensitivity" using the 100% Cs-13 7 option with detector end cap no greater than 3 inches from the surface, a 0.2206 µR/hr/pCi/g value for a detector to end cap distance of 3 inches, and a detector response for Cs-137 of940 cpm/µr/hr can be obtained. Using those values and a background of 8,000 to 10,000 cpm, the theoretical Cs-137 concentrations would be approximately 220 to 250 pCi/g.

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LaCrosseSolutions LC-2020-0023 Because the excavation was open, geometry would not factor into the increased gamma scan readings; however, the shine originating from the Reactor Building interior contents would contribute to the elevated results of the scan survey. The activity concentrations of 5 pCi/g of Cs-137 and 0.147 pCi/g of Co-60 are expected, since sampling was being performed as the excavation continued with radiological results indicating a lowering trend.

RAl-2d - Path Forward: The licensee should indicate whether the FSS scans reflected what they expected given the RASS scan data. Indicate whether additional remediation of the RPGPA survey unit was conducted after the RASS that was completed on December 6, 2017.

RAl-2d - LaCrosseSolutions Response: The FSS scan data was as expected, and LaCrosseSolutions provides the following information for clarification. The pre-FSS scans were performed within the excavation and in close proximity to the Reactor Building which was contributing to higher background values within L 1-SUB-TDS B. An additional 2 feet of soil was removed from the southwest quadrant of the Trench Box on December 12, 2017. Three soil samples were obtained from the area after the soil was removed with concentrations of Cs-13 7 up to 5.32 pCi/g and concentrations of Co-60 up to 0.11 pCi/g. FSS scans were performed on the Geoprobe tubes at the surface. None of scans caused alarms, and scan results were fairly uniform. The release record for survey unit L 1-SUB-TDS B was revised to include a discussion of the surveys described above. The revised release record is included in this response.

RAI-3a - Path Forward: For areas that underwent continuing characterization, including the areas listed in Section 5 .3 .3 .4 of the LACBWR LTP where the licensee committed to performing continuing characterization, describe which release records include the description of the continuing characterization activities. Provide data (including GEL Laboratories analytical reports) for the continuing characterization where not already provided. This description should clearly indicate which release records contain information on the continuing characterization of the soil beneath and adjacent to the LACBWR Reactor Building. The description should also indicate which release record( s) contains information on the continuing characterization activities related to the soil beneath LACBWR Warehouses 1, 2, and 3.

RAI-3a - LaCrosseSolutions Response: Release records for survey units listed below have a description of continuing characterization in Section 3, except for survey unit L 1-010-101 C.

  • Ll-SUB-TDS
  • Ll-010-101 C
  • Bl-010-001
  • Bl-010-004
  • Ll-SUB-TDS A
  • Ll-SUB-TDS B
  • Ll-010-101
  • Ll-010-104
  • Ll-010-105
  • Ll-010-106
  • Ll-010-107
  • L2-011-101
  • L2-011-104 Page 7 of26

LaCrosseSolutions LC-2020-0023 For Ll-010-101 C, two systematic samples (Ll-010-101-FSGS-C06-SB and Ll-010-101-FSGS-C14-SB) collected during FSS were selected to double as continuing characterization samples.

Both samples were sent off-site for full suite radionuclide analysis, and the results are in the release record. The release record for survey unit Ll-010-101 C was revised to include discussion on the continuing characterization samples collected during FSS.

Off-site analysis reports from GEL were added through revision to the release records for the following survey units that did not provide them previously:

  • Ll-010-101
  • Ll-010-104
  • Ll-010-105
  • Ll-010-106
  • Ll-010-107
  • L2-0l 1-101
  • L2-011-104
  • Bl-010-001
  • Bl-010-004 Additionally, the on-site gamma spectroscopy reports for all relevant survey units that underwent continuing characterization were included through revision to the release records.

The release record for survey unit B 1-010-001 contains a discussion and summary of the concrete cores collected for continuing characterization; however, the release record did not discuss the GeoProbe samples collected adjacent to and beneath the Reactor Building. The BI-O10-001 release record was revised to include the discussion and data summary of soil continuing characterization for the Reactor Building.

The release record for survey unit L2-011-101 contains information on the continuing characterization (RA) of the soil beneath the warehouses.

The revised release records are included in this response.

RAI-3b - Path Forward: For areas that underwent continuing characterization, provide detailed calculations to estimate the actual IC dose for each individual sample result. The results of the analysis should demonstrate that the IC dose contribution did not exceed what was assumed in the LACBWR LTP (i.e., 2.5 millirem per year (mrem/yr) for all media).

RAI-3b - LaCrosseSolutions Response: LaCrosseSolutions calculated the IC dose for the survey units identified in the response to RAI-3a. The results have been supplied within each release record through revision. The results of the analyses demonstrate that the IC dose contribution from any continuing characterization sample did not exceed what was assumed in the L TP (i.e., 2.5 mrem/yr).

RAI-3c - Path Forward: For the Stack, Pipe Tunnel, and RPGPA Excavation (Survey Unit Ll-SUB-CDR), when estimating the IC dose contribution incorporate the results from sample NRC

  1. 4 and sample Sump Area #1 into the calculation, or provide justification for why they should not be included in the IC dose calculation.

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LaCrosseSolutions LC-2020-0023 RAl-3c - LaCrosseSolutions Response: The IC doses for samples NRC #4 and Sump Area #1 were calculated and will be supplied to the NRC in accordance with RAI-3a. The area that was excluded from Ll-SUB-CDR became Ll-SUB-TDS B, which includes the Sump Area #1 sample. The maximum IC doses in survey units Ll-SUB-CDR and Ll-SUB-TDS Bare 0.7314 mrem/yr and 0.6373 1mem/yr, respectively.

RAl-3d- Path Forward: For the RPGPA Excavation (Survey Unit Ll-SUB-TDS B), the licensee should address inaccuracies in Table 3-2 of the release record before subsequently estimating the IC dose, and should also describe why only three of the eight samples collected during continuing characterization were analyzed for the full suite of radionuclides.

RAl-3d - LaCrosseSolutions Response: LaCrosseSolutions acknowledges that although the L TP was followed in regard to the number of samples to be sent for off-site analysis (minimum of I 0%), the requirement that all samples sent off-site for continuing characterization are to be analyzed for the full suite of radionuclides was not followed. Consequently, the five samples (Ll-SUB-TDS-CJGS-B01-SB, Ll-SUB-TDS-CJGS-B02-SB, Ll-SUB-TDS-CJGS-B04-SB, Ll-SUB-TDS-CJGS-B05-SB, and Ll-SUB-TDS-CJGS-B07-SB) were sent to GEL Laboratories and analyzed for the full suite of radionuclides. No radionuclides were positively identified in any of the five samples.

The release record for survey unit Ll-SUB-TDS B was revised to correct Table 3-2 and add the new data from the additional full suite analyses. The revised release record is included in this response.

RAI-3e - Path Forward: If the dose contribution from the insignificant radionuclides exceeds what was assumed for any survey unit, assign an appropriate additional dose from the insignificant radionuclides when calculating the total dose for that survey unit.

RAI-3e - LaCrosseSolutions Response: The results ofIC dose assessments ("LACBWR IC Dose Calculations" spreadsheet provided electronically on the enclosure to the RAI response) reveal that the assumed dose contribution of 2.5 mrem/yr for all media due to IC was never surpassed. As such, no additional dose was added to the total dose for any survey unit, and no adjustment to the DCGLs was warranted in any case.

RAI-3f - Path Forward: For the buried piping survey units, the rationale for not collecting sediment and/or debris samples should be provided for the following survey units:

  • Circulating Water Discharge Pipe (S 1-011-102)
  • De-Icing Line (S2-01 l-103 A)
  • Circulating Water Intake Pipe (S2-011-103)
  • Storm Drain I (S3-012-109 A)
  • Storm Drain 3 (S2-011-101 A)
  • Storm Drain 6 (S2-011-101 B)
  • Storm Drain 4 (S3-012-102 A
  • Storm Drain 5 (S3-012-102 B)

The licensee should also provide additional information on why a minimum of one of the three sediment samples collected from survey unit Storm Drain 2 (Survey Unit S3-012-109 B) were Page 9 of26

LaCrosseSolutions LC-2020-0023 not analyzed for HTD radionuclides or the full suite ofradionuclides in Table 5-1 of the LACBWRLTP.

RAI-3f - LaCrosseSolutions Response: No sediment and/or debris was available to sample during the turnover and FSS of survey units S 1-011-102, S2-011-103 A, S2-011-103 B, S2-011-103, S3-012-109 A, S2-011-101 A, S2-011-101 B, S3-012-102 A, and S3-012-102 B. Turnover scans of the pipe openings indicated minimal residual activity. Characterization surveys were deemed redundant and compliance was immediately demonstrated through the acquisition of direct measurements and comparison against the OpDCGLs for buried pipe.

S3-012-102 B, Storm Drain 5, is a 30" internal diameter vitrified clay pipe that runs east-west underneath the northern portion of the Switchyard. During the FSS, higher than expected readings were identified and it was suspected that NORM in the vitrified clay was the reason. A piece of the pipe was obtained at the outfall to the Mississippi River and analyzed via on site gamma spectroscopy. No plant-related radionuclides were identified above their MDAs; however, concentrations ofK-40, Bi-214, Pb-214 and Pa-228 were identified greater than their respective MDAs. The release record for S3-012-102 B has been revised to include a discussion on the higher than expected readings, and the Gamma Spectrum Analysis report has been attached to the release record. The pieces of the vitrified clay pipe were disposed of; however, LaCrosseSolutions has obtained another sample from the same pipe at the outfall location and has sent the sample to GEL for analysis for the full suite of radionuclides identified in LTP Table 5-1. No radionuclides were positively identified in the off-site analysis of the vitrified clay pipe sample. The IC dose calculated for the sample is 0.0810 mrem/yr; therefore, no DCGL adjustment is warranted. The revised release record is included in this response.

The three sediment samples (S3-012-109B-FJGS-062-SM, S3-012-109B-FJGS-063-SM and S3-012-109B-FJGS-064-SM) obtained during the FSS of S3-012-109 B (Storm Drain 2) were sent to GEL for HTD analysis. Because the samples were obtained during FSS, Sr-90 was the only HTD ROC analyzed per Section 5.1 of the LACBWR LTP. The three sediment samples have been disposed of by GEL; however, LaCrosseSolutions has retrieved the three original sediment samples from Storm Drain 2 and sent to GEL for analysis for the full suite of radionuclides identified in L TP Table 5-1. The release record for survey unit S3-012-109 B has been revised to include the GEL analytical report. Only Cs-13 7 was identified in the off-site samples, at a maximum concentration of 4.97E-02 pCi/g. The maximum IC dose calculated for the samples is 0.0791 mrem/yr; therefore, no DCGL adjustment is warranted. The revised release record is included in this response.

The following discussion will be included in the EnergySolutions corporate Lessons Learned Database: if characterization surveys were not performed on a system, any sample media collected during FSS will be analyzed for the full suite of radionuclides as if it were a characterization, or continuing characterization sample.

RAl-3g- Path Forward: For the WGTV Basement (Survey Unit Bl-010-004), indicate whether additional remediation took place after the continuing characterization cores were taken. The licensee should describe whether the ISOCS results during FSS reflect their expectations, considering the Cs-137 values obtained from the continuing characterization cores'..'

RAI-3g - LaCrosseSolutions Response: No additional remediation took place in the WGTV Basement after the continuing characterization cores were obtained. The ISOCS results from the Page 10 of26

LaCrosseSolutions LC-2020-0023 survey reflect the expectations of the results with the cores. The highest ISOCS result, l.32E+7 pCi/m2 was obtained from the WGTV sump, which also had the highest Cs-13 7 concentration of 148 pCi/g. The value of 148 pCi/g when converted to pCi/m2 is 4.42E+6 pCi/m2. The mean and median of the systemic measurements of 5.77E+4 and 3.77E+4 pCi/m2, equate to 1.94 and 1.27 pCi/g of Cs-13 7. This is in line with the sporadic contamination within the area and the use of a 28.3m2 field of view for the !SOCS measurements.

RAI-4a - Path Forward: For the above-grade building survey units, provide the detailed calculations used to derive the detector efficiency values, as well as the procedures used to determine these detector efficiencies. In addition, explain the difference in the detector efficiencies reported in Table 5-19, "Typical FSS Instrument Detection Sensitivities," of the LACBWR LTP and the detector efficiencies applied to the above-grade building surveys (e.g.,

Table 7-2, "Detector Efficiencies," of the release record for the Genoa 3 Crib House (Survey Unit B2-010-102)). This information should include how the detection area of the Ludlum Model 44-116 probe was accounted for in the detector efficiency used in the above-grade building surveys.

RAI-4a - LaCrosseSolutions Response: Ludlum Model 2350-1 instrument and Ludlum Model 44-116 detector combinations were sent off-site to the EnergySolutions Bear Creek facility for calibration and efficiency determination. According to the procedure used at Bear Creek and LaCrosseSolutions procedure LC-RP-PR-060, Calibration and Initial Set-Up of the 2350-1, the process for efficiency determination of the Ludlum Model 2350-1 instrument and Ludlum Model 44-116 detector involves placing the detector, which has a 125 cm2 active window area and a 100 cm2 open window area, on a 125 cm2 area Tc-99 source and collecting 20 one-minute measurements. The average of the 20 measurements is divided by the source activity to determine the efficiency. Because of the metal hex pattern that covers and protects the 125 cm2 window of the detector, the area of the detector is corrected to 100 cm2 . Because of the open window area of the detector being 100 cm2, FSS measurements in cpm can be converted directly to dpm/100 cm2 by dividing the activity in cpm by the efficiency of the detector.

Table 5-19 of the L TP lists "typical" instrumentation and efficiencies. Actual calculated efficiencies (typically in Table 7-2 of the relevant release records) were used during the performance of FSS. A copy of procedure LC-RP-PR-060, Calibration and Initial Set-Up of the 2350-1 is included with this response.

RAI-4b - Path Forward: For the above-grade building survey units, provide additional justification for why the applied radionuclide mixture is representative for the above-grade buildings. Show that the efficiency of the detector and the Gross OpDCGL are both appropriate, given the potential variation in relative radionuclide concentrations within above-grade buildings. Specifically, provide information on the representativeness of the detector efficiency calculations for the range of radionuclide mixtures within the buildings. This information should address changes in instrument response that would, in turn, alter the count rate (cpm) and calculated surface activity (dpm/100 cm2), such as a higher instrument efficiency decreasing the calculated surface activity. Similarly, provide information on potential changes to the calculated Gross DCGL for corresponding changes in the relative radionuclide concentrations for the above-grade buildings.

Page 11 of 26

LaCrosseSolutions LC-2020-0023 RAI-4b- LaCrosseSolutions Response: Section 5.1 of the LTP provides discussion on the radionuclides of concern and mixture fractions used for FSS. The radionuclide mixture fractions for soil and pipe are based on the results of concrete cores obtained during characterization of the Reactor Building, Waste Treatment Building and the balance of the basement structures (primarily the Piping Tunnels). Table 5-2 presents the ROC for the decommissioning of LACBWR and the normalized mixture fractions based on the radionuclide distribution from TSD RS-TD-313196-001. The radionuclide mixture fractions for Soil/Pipe identified in Table 5-2 are intended to be applied to above-grade buildings and other materials not associated with the Reactor Building or Waste Gas Tank Vault. Section 5.1 also discusses the requirements for HTD analyses during continuing characterization and FSS to verify there are no changes to the ROC and mixture fractions. During continuing characterization and FSS, there were no instances where the results of the HTD analyses triggered a change to the ROC or mixture fractions; therefore, the radionuclide mixture in Table 5-2 is representative for the above-grade buildings.

The instrumentation utilized for the surveys of the above grade structures at LACBWR were calibrated with Tc-99. Tc-99 has a lower beta energy than the five radionuclides of concern at LACBWR with a maximum beta energy of 0.294 MeV. Only Eu-152 and Eu-154 have beta emissions with less energy, which have emissions of low abundance with lower energies. Eu-152 emits a beta with a maximum energy of 0.178 MeV with an emission percentage of 1.83%. Eu-154 emits a beta 28.3% of the time with a maximum energy of 0.249 MeV. All other emissions from Eu-152 and Eu-154 with percentages greater than one have beta energies greater than 0.294 MeV. Since the instruments were calibrated with Tc-99, the instrument efficiency will be lower than if the instruments were calibrated with Cs-137 or SrN-90. The stated efficiencies for Tc-99 and Sr/Y-90 from the manufacturer's literature are 15% and 30%, respectively. Since any residual contamination present in the above grade buildings (see also response to RAI-4c) would have instrument efficiencies higher than that of an instrument calibrated with Tc-99, the resulting counts per minute would be the same, but the calculated dpm/100cm2 would be higher due to the lower instrument efficiency utilized for Tc-99. This results in conservative survey measurements when converted for dpm/100cm2

  • RAI-4c - Path Forward: Provide a discussion of how the survey approach used for the above-grade buildings accounted for the 10 percent IC radionuclide dose that was committed to in Section 6.14.1, "Insignificant Contributor Dose and Radionuclides of Concern," of the LACB WR L TP. This section of the L TP states that "the IC dose percentage assigned to adjust the DCGLs for the ROC in all media (soil, basements, buried pipe, and above-grade buildings) is increased to 10 percent." If 10 percent was not assigned to the IC radionuclides dose, state so, and provide a technical basis for why those radionuclides would not be expected to be present in the above-grade buildings.

RAI-4c - LaCrosseSolutions Response: The adjusted DCGLs utilized for the above grade buildings were not adjusted for the 10 percent IC dose. However, as described in the response for RAI-4b, the utilization of Tc-99 for the instrument efficiency would compensate for the IC dose for the buildings. A difference of2.3% from a detector efficiency of20% and 1.7% from a detector efficiency of 15% would result in dpm values with a difference of 10%. Additionally, the radionuclide mixture was evaluated to determine if the ratios of the five main ROC had changed as well as the IC contribution. Using the data from soil samples as discussed in the IC RAis, and the average concentration of the ROC, the following table was derived:

Page 12 of 26

LaCrosseSolutions LC-2020-0023 Soil Data (Including Negative Data)

Average Concentration Percentage of Radionuclide (pCi/g) Total Co-60 5.07E-01 7.S0E-02 Sr-90 1.22E-01 1.S0E-02 Cs-137 6.1 lE+00 9.03E-01 Eu-152 1.04E-02 1.54E-03 Eu-154 l.SlE-02 2.24E-03 6.77E+00 1.00E+00 The same methodology was used for all the data. The following table presents the results:

All Data (Including Negative Data)

Average Concentration Percentage of Radionuclide (pCi/g) Total Co-60 5.45E-0l 4.0SE-02 Sr-90 l.S0E-01 1.12E-02 Cs-137 1.27E+0l 9.47E-0l Eu-152 4.65E-03 3.47E-04 Eu-154 1.24E-02 9.26E-04 l.34E+0l 1.00E+00 The percentage of the total of Cs-13 7 to the other ROCs went up in both cases when compared to the Cs-137 value in Table 41 ofRS-TD-31319-001, Revision 5 of0.829. As such, when adjusting the gross activity DCGLs utilizing Equation 4-4 ofMARSSIM, the DCGLs go up. The following presents the recalculation results.

Adjusted Base Case DCGL (dpm/100cm 2)

RS-TD-31319-001 Soil Data All Data 19,751 22,124 24,420 Both of the DCGLs went up by more than 10%, which would lower the dose assigned to the unit.

This, in combination with the use of Tc-99 efficiencies, compensate for the IC dose.

The data set was also examined to verify that the IC dose was insignificant when compared to the five main ROCs. When negative data is left in the data set, the dose contribution is negative for the IC radionuclides. The percentage of the total mixture for IC radionuclides is 35.88, compared to 33.28 presented in RS-TD-31319-001, Revision 5. No change for the IC dose is necessary.

RAI-4d - Path Forward: For the buried piping survey units, for any samples that were analyzed for individual radionuclide activities, the licensee should compare the results to the assumed radionuclide mixture fraction used to calculate the Gross OpDCGL. In addition, the licensee should provide a copy of the LACBWR procedures used for calculating the MDCs for piping, Page 13 of26

LaCrosseSolutions LC-2020-0023 including documents that describe detector efficiency calculations for different size piping (see RAI-6 for additional information).

RAl-4d- LaCrosseSolutions Response: Only Cs-137 was detected in sediment samples. As such, no change to the radionuclide mixture fraction is needed. Copies of procedure LC-FS-PR-018, Radiation Surveys of Pipe Interiors using Sodium/Cesium Iodide Detectors and TSDs LC-FS-TSD-005, MCNP Modeling of Water Discharge Pipes for the LaCrosse Boiling Water Reactor and LC-FS-TSD-003, Assessment of the LACBWR Circulating Water Discharge Pipe Final Status Survey Data for Detection Efficiency and Detector Background are included with this response.

RAI-Sa- Path Forward: Each of the 14 Phase 3 LACBWR FSS Reports reference a comparison of K-40 concentrations in the original and QC samples as the rationale for accepting the failure of the QC check; 9 of the 17 Phase 2 reports reference Operational DCGLs as the rationale for accepting the failure of the QC check; and 9 of the 10 Phase 1 reports have a combination of these rationales for accepting QC failures. The licensee should review each of the PSS reports that contained QC check failures and provide a description of the investigation(s) and outcome(s) associated with these quality assurance activities, consistent with the commitments in Section 5.9.3.4 of the LACBWR LTP.

At a minimum, the discussion of these QA/QC topics should address the following:

  • How quality assurance protocols were followed during collection and analysis of these samples (e.g., measurement instrument performance checks, MDCs for the original and QC sample measurements, chain of custody, etc.).
  • For original and split samples with results greater than the MDC, explain why the QC checks failed the acceptance criterion for compared sample results. If the subsequent investigation and/or discussion reveals the survey data is suspect and may not represent actual conditions in the survey unit, provide infonnation on the collection of additional measurements, the usability of the survey data, and the potential for the discrepancy to adversely affect the decision on the radiological status of the overall survey unit.
  • Provide a discussion of the supplementary QC steps that were taken, in addition to the use of a K-40 concentration comparison, in the data assessments for the survey units. The NRC staff notes that K-40 should not, by itself, be considered a substitute for explaining the QC assessment results. The licensee should supplement the QC analyses with other data analysis considerations and/or discussion of the various QA/QC processes that lead to confidence in the data assessment results ( e.g., different MDCs for the ROCs in the samples, heterogeneity of soil samples, use of spiked samples, sample reanalysis, etc.).
  • Please describe the QC steps used for the !SOCS measurements, including the use of duplicate measurements and comparisons to core sample analysis for the survey units where !SOCS was a primary measurement instrument. Clarify whether NRC Inspection Procedure 84750, "Radioactive Waste Treatment and Effluent and Environmental Monitoring," was used for !SOCS QC measurements.

RAI-Sa - LaCrosseSolutions Response: In order to assure conformance with established regulatory requirements, and to ensure the adequacy of data used to demonstrate that site conditions are acceptable for release of the site from the facility license, LaCrosseSolutions Page 14 of26

LaCrosseSolutions LC-2020-0023 developed a comprehensive QA Program that includes a QAPP and Section 5.9 of the LTP. All radiological survey activities essential to data quality were implemented and performed using trained and qualified individuals, using written procedures and properly calibrated instruments that are sensitive to the potential radiological contaminants.

Instrument quality and control was achieved using the requirements specified in approved procedures and in Section 5.1 of the QAPP. Instrument control was implemented through the receipt, inspection, issue, control and accountability of all portable radiological instrumentation used for FSS. Response checks were performed on all radiological instrumentation and/or detectors used for FSS prior to and following each use. Instrument calibration and frequency was performed using the requirements specified in approved procedures and in Section 5.2 of the QAPP. Survey data control from the time of collection through evaluation was specified by procedure, survey package instructions, and Section 5.5 of the QAPP.

Data validation and usability was performed using the DQA method in accordance with approved procedures. Data review, verification and validation was performed in accordance with procedures and Section 6.2 of the QAPP. For samples sent off-site for HTD analyses, an accredited laboratory was used. The V & V of all data included the verification of the absence of anomalies in the sample or measurement results, or in the supporting data, including but not limited to MDC, uncertainty, deviation from established procedure or analysis flags.

Effective implementation of the radiological survey operations was verified through audit and surveillance activities, including field walkdowns by management and supervisory staff, program self-assessments, and independent third-party technical reviews of all sample plans, release records and final reports.

LaCrosseSolutions performed a review of all survey units to ensure that QA/QC protocols described in the QAPP and Section 5.9 of the LTP were followed. The following are the acceptance criteria for QC assessments:

  • For all QC assessments, agreement is ultimately determined if the same conclusion is reached in the comparison. This conclusion is interpreted, for the QC assessments of the LACBWR FSS, as both the standard and comparison samples/measurement activities being below the OpDCGL.
  • The acceptance criteria for replicate static measurements is that the same conclusion is reached for each measurement. This is defined as the replicate measurement being within 20% of the standard measurement. In cases where the replicate measurement is not within an acceptable agreement, while not proceduralized, Radiological Engineers used a reasonable range of +/-20% as a tool to determine if the measurements reach the same conclusion. In addition, the Radiological Engineer would also assess the dose represented by each measurement to determine agreement. The acceptable agreement of QC measurements taken using gross gamma measurements from a standard hand-held NaI detector (e.g., buried pipe) were assessed using this criterion.
  • The acceptance criteria for duplicate or split samples is specified in Inspection Procedure No. 84750, Radioactive Waste Treatment, and Effluent and Environmental Monitoring, which utilizes the table below. The "Resolution" in the table is equivalent to the activity divided by the standard error in the standard sample. The "Acceptance Ratio" is equivalent to the activity of the comparison sample divided by the activity of the standard Page 15 of 26

LaCrosseSolutions LC-2020-0023 sample.

Resolution Acceptance Ratio

<4 0.4- 2.5 4-7 0.5 - 2.0 8-15 0.6-1.66 16-50 0.75 -1.33 51-200 0.8-1.25

> 200 0.85-1.18 LaCrosseSolutions performed an extent of condition review with regard to QC assessments for all survey units. Only two QC assessment failures occurred, one in survey unit Ll-SUB-CDR and one in L 1-SUB-TDS. In these instances, the duplicate/split samples were being compared to their standard samples using Cs-137 for the assessments. In both instances the Cs-137 concentration in the standard samples were approximately 60% to 75% higher than the comparison samples. The investigation included performing the QC assessments using K-40 results, which determined there was an acceptable agreement between standard and comparison samples. This result should have been presented in the release records with additional comments.

Rather, the Cs-137 activities for the standard and comparison samples were compared with the OpDCGL and found to be well below the OpDCGL (i.e., the same conclusion was reached),

which prompted acceptance of the QC results. Section 8 and Attachment 4 of the release records for survey units Ll-SUB-CDR and Ll-SUB-TDS will be revised to reflect the findings from the investigations. LaCrosseSolutions is confident that the investigations performed verify the survey data is acceptable and represents actual conditions in the survey unit.

Cs-137 was typically the radionuclide to be used for QC assessments. This was based upon the predominance of Cs-13 7 in the characterization soil sample results. Using this radionuclide was not a commitment in the LTP, QAPP, or PSS procedures. LaCrosseSolutions acknowledges that K-40 should have been the primary radionuclide with which to do QC assessments because of the non-homogenous nature of the activity in split or duplicate samples.

The substitution of K-40 in QC assessments does not mean initial assessments resulted in failure.

In cases where Cs-13 7 was not detected in one or both of the standard and comparison samples, the assessment could be performed. If Cs-13 7 was detected in both samples with activity levels just above MDC, performing the QC assessment does not have a high level of confidence. When the test could not be run using Cs-137, K-40 was used, which is easily detectable and identified in nearly all samples.

ISOCS measurements were obtained in survey unit Bl-010-001, Reactor Building Basement, and survey unit Bl-010-004, Waste Gas Tank Vault Basement. Section 8 of the release records generated for each of these basements describes the QC assessments performed for the measurements. In accordance with Section 5.9 of the LTP, replicate measurements were taken during PSS at a frequency of 5% of the compliance measurements. The replicate measurement consisted of a repeat IO-minute count (usually) at the exact location of the original measurement.

The measurement results were evaluated using NRC acceptance criteria specified in Inspection Procedure No. 84750. A summary of the QC analyses performed for ISOCS measurements is provided below:

Page 16 of26

LaCrosseSolutions LC-2020-0023

  • B1-010-001: Three (3) replicate measurements were obtained during FSS. In all three (3) pairs of standard and comparison measurements, there was acceptable agreement. In two (2) of the locations, K-40 was substituted for Cs-137 was not identified in either the standard or comparison measurement. For the other location, K-40 was substituted for Cs-13 7 because low Cs-13 7 activity was identified in the replicate measurement and no ROC were identified in the standard measurement.
  • B1-01-004: Two (2) replicate measurements were obtained during FSS. Inspection Procedure No. 84750 could not be used to for QC evaluation because in the case of both pairs of standard and comparison measurements, there were no mutually identified radionuclides, and the method for acceptance of the procedure could not be utilized. In this case, both pairs of standard and comparison measurements contained insignificant or no detectable radioactivity and all were well below the OpDCGLB, and because the ISOCS unit was properly calibrated and passed the pre- and post-use response check, no further action was deemed necessary. This is further backed up by Section 4.1.2 of the QAPP that states, "Agreement is ultimately determined when the same conclusion is reached for each compared result." For both pairs of standard and comparison measurements, the same conclusion was reached (all results were well below the OpDCGLB).

In accordance with Section 5 .1 of the LTP, concrete core samples were required to be collected at 10% of the I SOCS measurement locations. The purpose of the core sampling was for HTD analysis and therefore, the comparisons of core sample analyses to ISOCS measurements was not required or performed for QC purposes.

The revised release records are included in this response.

RAI-6a - Path Forward: The licensee should explain whether the data listed in Table 7-3 of the Genoa 3 Crib House (Survey Unit B2-010-102) release record is for net radiological survey measurements (residual radioactivity minus background radioactivity) or gross radiological survey measurements (summation ofresidual radioactivity and background).

RAI-6a - LaCrosseSolutions Response: The data in Table 7-3 of the release record for survey unit B2-010-102 and in the equivalent tables in all other above grade building survey unit release records represent residual radioactivity minus background activity. The term "gross activity" is used to indicate that the values represent the total surface activity of all ROC as compared to the Adjusted Gross DCGL.

RAI-6b - Path Forward: The licensee should explain which FSS release records excluded background in the radiological survey data, and which FSS release records included background in the radiological survey data. This information could be provided in tabular format. As part of this explanation, the licensee should explain the rationale for not following the commitment in Section 5.6.4.2 of the LACBWR LTP to not subtract background when demonstrating compliance with the unrestricted radiological release criteria.

RAI-6b - LaCrosseSolutions Response: All above grade building and buried pipe survey units exclude ambient background in the survey data, with the exception of one buried pipe survey Page 17 of 26

LaCrosseSolutions LC-2020-0023 unit (S2-0l 1-103), where the exclusion of ambient background would have created an overabundance of negative data.

For land areas, the typical statistical test scenario in MARSSIM is "the contaminant is present in background." In this instance, the Wilcoxon Rank Sum test, which compares background reference area data to site survey unit data, would be the appropriate statistical test to demonstrate compliance. In order to facilitate the simpler statistical test (Sign test) that doesn't require the establishment of reference areas, and because background from global fallout is a small fraction of the DCGLs for soil, the scenario in which "the contaminant is not present in background" was selected; thus, background from fallout was not subtracted from soil samples, and the Sign test was used to demonstrate compliance. For above grade buildings and buried pipe, however, ambient background is subtracted from all measurements, and the Sign test is used to demonstrate compliance.

The process followed for the FSS of above grade buildings and buried pipe is in line with MARSSIM guidance and standard industry practice. LaCrosseSolutions acknowledges that the language in the LTP should have been clarified. For future LTPs, EnergySolutions will make a clearer distinction between ambient background and background from fallout and how background will be applied to survey data.

RAI-6c - Path Forward: The licensee should provide the detailed calculations used to derive detector efficiencies and explain the difference in the detector efficiencies reported in Table 5-19 of the LACB WR L TP and the detector efficiencies applied for the above-grade building survey units (e.g., Table 7-2 of the release record for the Genoa 3 Crib House). This information should include how the detection area of the Ludlum Model 44-116 probe was accounted for when calculating the detector efficiency used for the above-grade building survey units and during the calibration procedure (see RAI-4 for additional information).

RAI-6c - LaCrosseSolutions Response: See LaCrosseSolutions' response to RAI-4a.

RAI-6d - Path Forward: The licensee should provide the procedure used for determining background radioactivity in the above-grade building survey units. The licensee should describe how the measurement locations were chosen, as well as how a representative "background" measurement was acquired with the Ludlum 44-116 probe. This description should state whether a beta shield was used with the probe, and in what position the detector was held when background measurements were taken (facing up or facing down).

RAI-6d - LaCrosseSolutions Response: The collection of backgrounds for above-grade building survey units was not a procedural process. Rather, guidance on the proper collection of backgrounds was provided in training and reiterated through job briefings and field instructions from the Supervisors.

Background measurement locations were selected as to provide a representative spread of ambient background. For example, five backgrounds could have been collected on one building elevation or a single room (a typical method is four comers and the center), as long as the measurements represented true ambient background to the scan areas and static measurements for which they were used.

Page 18 of 26

LaCrosseSolutions LC-2020-0023 To perfonn a background measurement, the unshielded Ludlum Model 44-116 detector was held approximately waist high with the detector face pointed away from the surface of interest.

RAI-6e - Path Forward: The licensee should provide a revised set of figures for sample locations in the above-grade building survey units (e.g., Figure 16-1 though Figure 16-4 of the Genoa 3 Crib House release record) that clearly illustrate where background measurements and static measurements were taken, as well as the areas where scanning was conducted in the survey unit. The revised figures should clearly shade or outline the areas where scans, background, and static measurements were taken. If static measurements were not taken at the locations shown on the grid in the revised figures, the licensee should provide an explanation for not taking measurements at those grid locations. For example, the presence of obstructions that interfered with taking static measurements at the grid locations should be described, or other considerations should be discussed.

RAI-6e - LaCrosseSolutions Response: LaCrosseSolutions perfonned a review of the , Figures and Maps, for all above-grade building survey units. With the exception of survey unit B2-010-101, LACB WR Crib House, the locations of all systematic, random and judgmental static measurement locations are correctly shown on the figures. For survey unit B2-010-101, three of the static locations were relocated from the location originally prescribed in VSP to account for elevated readings identified during the scan survey (see RAI lf).

The locations where background measurements were obtained were not noted on survey maps or marked in the field as procedures and sample plans did not require the locations to be noted or marked. It is not possible to revise the figures in Attachment 1 for any of the above-grade survey units. RAI 6d provides a description of the background measurement collection process which may help the reviewer understand approximately where the background measurements were obtained.

The locations where scanning was conducted were not noted on survey maps, but the locations were marked in the field. Photographs of the scan locations were taken and placed within the field notes for each survey unit. A general description of the total size of the scan area is provided in Section 5, Survey Design, of each survey unit. In some instances, details of the amount of scanning around each static measurement is provided. The field notes, for each survey unit, indicate the area scanned around each static location (random, systematic and judgmental). With the exception of survey unit B2-010-101 (see RAI If), there were no scan alarms encountered during the FSS of above-grade buildings. All scan results are provided in Table 7-1 within each release record. Given that the amount of surface area, where scan surveys were conducted, was provided (thus ensuring the minimum scan frequency was met), along with the results for each scan, LaCrosseSolutions does not believe there is added value in depicting the scan locations on figures provided in the release records for above-grade building survey units.

RAI-6f - Path Forward: The licensee should explain why the background data is "blanked out" in, for example, Attachment 6, "Ludlum 2350-1 Download Reports," of the Genoa 3 Crib House release record, as well as other release reports. For example, state whether this is due to a spreadsheet formatting issue or as a result of output from the Ludlum 2350-1 ratemeter. In addition, state which data values in Attachment 6 were used to calculate the average background for each detector.

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LaCrosseSolutions LC-2020-0023 RAI-6f- LaCrosseSolutions Response: The column of the download reports labeled "BKG" denotes identifiers for pre- ("PRBKG") and post-use ("PSBKG") background response checks.

Field background identifiers ("FLDBK") are provided in the "Location" column, and the values that follow to the right in the "Logged Reading" column are used to calculate the average backgrounds.

RAI-6g- Path Forward: The licensee should provide the procedure used for determining background radioactivity in the buried piping survey units. The locations where the background measurements were acquired for the buried piping should be described and a discussion of why this was a suitable reference area should be provided.

RAI-6g - LaCrosseSolutions Response: The methodology for determining background radioactivity in the buried piping survey units utilized the same piping detector configuration as the calibrations. Originally, clean piping of various sizes was placed on the ground adjacent to the Administration Building. This location was found to have elevated backgrounds due to proximity to the Reactor Building. The piping was then moved to the northern portion of the site and placed on the ground. When the data from piping surveys was being reviewed, it was decided to bury the piping, since the background values were elevated, resulting in large amounts of negative data. It was suspected to be caused by terrestrial background radioactivity. The piping was placed on a concrete pad surrounded with concrete barriers. Clean fill was placed on the concrete pad with the pipes on top. Clean fill was then placed on top of the pipes to mimic a buried pipe. The survey unit in which this operation occurred, L3-012-101 was surveyed at the end of the project with a maximum Cs-137 concentration in soils of 0.166 pCi/g. A copy of TSD LC-FS-TSD-003, Assessment of the LACBWR Circulating Water Discharge Pipe Final Status Survey Data for Detection Efficiency and Detector Background is included with the response.

RAI-6h - Path Forward: Please explain the method that was used to determine the detector efficiencies for various sized buried piping. Include in the explanation the relevant supporting technical documents for determining the detector efficiencies used for each diameter size of piping and material type (e.g., TSD LC-FS-TSD-005, "General Monte Carlo N-Particle (MCNP)

Modeling of Water Discharge Pipes for the La Crosse Boiling Water Reactor," and TSD LC-FS-TSD-003, "Assessment of the LACBWR Circulating Water Discharge Pipe Final Status Survey Data for Detection Efficiency and Detector Background").

For the efficiency factor determination of buried piping, please explain how a background range is determined for the different sized piping and materials, considering that Section 4.1 of the associated procedure (TSD LC-FS-PR-018, "LACBWR Site Restoration Project Radiation Surveys of Pipe Interiors Using Sodium/ Cesium Iodide Detectors," Revision 0) indicates that only one background measurement is to be taken to establish a background range for each buried piping survey unit.

RAI-6h - LaCrosseSolutions Response: The detector efficiency for piping was determined with the use of a flexible Cs-13 7 source. The source size is one foot by one meter in width. The detector was placed in the piping jig utilized for surveying. The jig was moved over the source at various intervals and one minute static measurements were obtained. Seven of the intervals are averaged, background subtracted, and the result divided by the activity of the source. TSD LC-FS-TSD-005, "General Monte Carlo N-Particle (MCNP) Modeling of Water Discharge Pipes for the La Crosse Boiling Water Reactor," and TSD LC-FS-TSD-003, "Assessment of the Page 20 of26

LaCrosseSolutions LC-2020-0023 LACBWR Circulating Water Discharge Pipe Final Status Survey Data for Detection Efficiency and Detector Background" were developed to evaluate the efficiencies as detennined above for various sizes of pipe present at LACBWR due to the detector having a larger field of view than the calibration source. The TSDs utilized MCNP calculations to model the interactions of photons with a detector in a uniformly contaminated pipe for various diameters and lengths of piping. For each pipe geometry, a correction factor was calculated. The correction factor is a ratio of the response of the detector to a uniformly contaminated source to the response of the calibration source. This correction factor is then utilized to adjust the efficiency of the detector, determined by utilizing the calibration source, for the detector's field of view.

Background determination for the efficiency factor was determined by taking a ten minute static count while the detector was in the pipe survey jig inside the pipe. A control of+/- 20 percent of that cpm value was then placed on the pre and post background checks.

The relevant supporting technical documents are TSD LC-FS-TSD-005, General Monte Carlo N-Particle (MCNP) Modeling of Water Discharge Pipes for the La Crosse Boiling Water Reactor, and TSD LC-FS-TSD-003, Assessment of the LACBWR Circulating Water Discharge Pipe Final Status Survey Data for Detection Efficiency and Detector Background. They are included with this response.

RAI-6i- Path Forward: Section 4.1.10 ofTSD LC-FS-PR-018 states that "a separate efficiency factor determination must be determined for each size of pipe that will be surveyed with the detector and data logger pairing. Efficiencies determined for larger piping diameters may be utilized for piping of a smaller diameter and construction material." This is also restated in Section 4.3 of the procedure. Please provide the technical justification for applying detector efficiencies determined for larger piping diameters to piping of a smaller diameter. The NRC staff recognizes that this point might be superseded by the licensee's response to the above bullet in the path forward for this RAI.

RAI-6i - LaCrosseSolutions Response: Larger diameter piping of the same type of construction results in a lower detector source efficiencies. This is due to the increased overall distance from the source and due to the source being conformed to a pipe oflarger diameter. Photons from the source to the sides of the detector travel a longer distance and have a larger intercept angle to the detector. In experiments, concrete piping of 48", 33", and 24" diameters had detector efficiencies (counts/disintegration) of3.31E-3, 3.57E-3, and 4.03E-3, respectively.

RAI-6j - Path Forward: Section 4.2 of TSD LC-FS-PR-018 does not include a pre-use operational check of the survey equipment with a check source to determine proper instrument response. Instead, the pre-use operational check includes a background measurement of the detectors. Please explain the reason for not determining proper instrument response with a check source prior to performing a pipe survey, as well as during the operational checks of the survey equipment that are performed twice per day during use.

RAI-6i - LaCrosseSolutions Response: Instruments were source checked before and after the surveys. Instrument response checks are mentioned in Section 3.3.3.8, notes after 4.2.12 and 4.3, and Section 4.3.15 of LC-FS-PR-018.

RAI-6k - Path Forward: Procedure TSD LC-FS-PR-018 provides effective detection area estimates for two sizes of buried piping. An effective detection area of 3,050 cm2 is applied to Page 21 of26

LaCrosseSolutions LC-2020-0023 pipes greater than 13 inches in diameter; for pipes that are 10 inches in diameter, an effective detection area of 2,432 cm2 is used. Please provide additional information on the derivation of these effective detection areas for buried piping.

RAI-6k - LaCrosseSolutions Response: The use of 3,050 cm2 is used for larger diameter pipes and is the size of the conforming source (1 m by 1ft). The use of2,432 cm2 for ten inch diameter piping is derived from the circumference of a ten inch pipe and assuming a one foot length for the detector field of view (2*rr*r*h = 2*3.1415*12.7cm*30.48cm = 2432cm2).

RAI Path Forward: The licensee may choose to revise the above-grade building and buried piping survey unit FSS release records to include background prior to comparing the survey data to the unrestricted release criteria. However, the licensee should still provide a discussion regarding the above requested information on the measurement procedure for acquiring representative background in above-grade building and buried piping survey units.

RAI LaCrosseSolutions Response: LaCrosseSolutions chooses not to revise the above-grade building and buried piping survey unit FSS release records to include background prior to comparing the survey data to the unrestricted release criteria. This decision is based on confidence that the methods used to establish ambient background levels are industry standard and would produce a true representation of background. A discussion regarding the procedure for acquiring representative background in above-grade buildings and buried piping is provided in the response to RAis 6d and 6g.

RAI-7a - Path Forward: Describe how radionuclide concentration data from the onsite LACBWR gamma spectroscopy laboratory and the off-site GEL Laboratories measurements for the same samples were evaluated and compared under the LACBWR QAPP.

I RAl-7b - Path Forward: Provide additional information on the samples analyzed by both laboratories. For example, provide information on whether the samples analyzed by each laboratory were the same sample, split samples, or separate samples taken from the same location. In addition, provide information on differences in sample preparation between the two laboratories, and any other differences (e.g., analytical method) that could explain why the onsite laboratory generally reported lower concentrations than GEL Laboratories.

RAl-7c - Path Forward: Given the pattern of the onsite measurements being generally less than the measurements made by GEL Laboratories, additional justification is needed to provide assurance that the onsite gamma spectroscopy results were not consistently underreporting the concentration of residual radioactivity in the samples analyzed onsite.

RAI-7d - Path Forward: Provide additional information or discussion of the reason for the significant difference in the reported concentration values for Cs-137 and Co-60 in sample NRC-CDR #4 from the Stack, Pipe Tunnel, and RPGPA Excavation (Survey Unit Ll-SUB-CDR).

RAI-7a-RAI-7d- LaCrosseSolutions Response: LaCrosseSolutions performed an extent of condition review for RAis 7a, 7b, 7c, and 7d. The following are the results of the review.

Laboratory Comparison Sample results for Cs-137 were evaluated using the methodology described in NRC Inspection Procedure No. 84750. The results were acceptable in 45 of the 74 sample comparisons, and all Page 22 of26

LaCrosseSolutions LC-2020-0023 but 15 when both samples had Cs-13 7 detected. Results were acceptable in 5 of 6 comparisons with the USDOE Radiological and Environmental Sciences Laboratory. The sample results were also evaluated using the methodology presented in Appendix C of the Multi-Agency Radiological Laboratory Analytical Protocols (MARLAP) manual. The results of the evaluation indicated that 71 of the 74 comparisons were below the warning limit.

Sample Origination The samples sent off-site to the GEL laboratory were split samples, a sample in which the original sample aliquot is separated into two aliquots and analyzed as separate samples. The reasoning behind not sending the same sample that was analyzed on-site is that in GEL analyses, hard to detect radionuclides, particularly tritium, can be driven out of samples that have been dried. LACBWR dries samples prior to analyses. The use of split samples can produce differing results since small pockets of elevated activity may be transferred to one sample and not the other.

Sample Preparation A comparison of sample preparation methods between the GEL and LACBWR laboratories was performed. There are differences in the two laboratories that may create discrepancies that could lead to the GEL laboratory reporting results with higher concentrations than the LACBWR laboratory. This is particularly in regards to homogeneity and particle size of the sample to be analyzed. LACBWR mixed the sample, placed a sample aliquot into a drying pan, dried the sample, broke up the dried sample by hand, removed large stones, rocks or twigs greater than one centimeter, and placed into a Marinelli container for analysis. GEL's sample preparation method produces a more homogenous sample with a smaller particle size than the LACBWR methodology, which could produce consistently higher results when analyzed due to the smaller particle size and lack of radiologically benign small stones or rock that might be present in the LACBWR prepared sample.

GEL Laboratory Intercomparisons An investigation into GEL Laboratories participation in laboratory intercomparisons was made.

GEL participates in the US Department of Energy's Radiological and Environmental Sciences Laboratory Mixed Analyte Performance Evaluation Program (MAPEP). The MAPEP reports were reviewed for the period ohime LACBWR was performing Final Status Surveys. GEL had acceptable results, during the period, for the analysis of Cs-13 7, but consistently had a higher bias than the standards sent for evaluation. The following are the results of the intercomparison for Cs-137:

Reference Date Study Identifier Positive Cs-137 Bias 02/01/17 MAPEP-17-MaS36 11.1%

08/01/17 MAPEP-17-MaS37 6.9%

02/01/18 MAPEP-18-MaS3 8 NIA- Sensitivity Evaluation 08/01/18 MAPEP-18-MaS39 4.5%

02/01/19 MAPEP-19-MaS40 10.8%

08/01/19 MAPEP-19-MaS41 9.6%

02/01/20 MAPEP-20-MaS42 3.9%

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LaCrosseSolutions LC-2020-0023 Dose Assignment A study was conducted to see the potential impacts of dose assignment with the two data sets.

LaCrosseSolutions assigns the activity for each gamma-emitting radionuclide in the following manner: the actual recorded value will be used as the recorded FSS result for measurement and/or sample values that are less than MDC. Negative values will be recorded as "zero." The value for the highest percent abundance energy line with positive results will be used for reported results for radionuclides with multiple gamma energies. The highest positive result will be recorded for radionuclides with energy lines with equal abundance (i.e., Co-60). If all energy lines are negative, "zero" will be recorded. This is a conservative approach, particularly for Eu-152 and Eu-154 at LACBWR, which have multiple energy lines and the three most prominent energy lines evaluated. Eu-152 and Eu-154 also have relatively low OpDCGLs at 8.51 and 7.89 pCi/g. The comparison was made using the reported results from GEL. Concrete cores were not evaluated since the compliance method is through the use of I SOCS measurements. The results of the comparison for the highest sample for dose being the same sample, Ll-SUB-CDR-FSGS-009-SB, with 4.135 and 7.623 mrem/yr for LACBWR and GEL, respectively. However, the data set on average was 28% higher for the LACBWR results than the GEL data set at 0.672 versus 0.525 mrem/yr, respectively.

Sample NRC-CDR #4 Sample NRC-CDR #4 is believed to have been split from a different sample coming from the RPGP A area, which was split from the unit due to necessary remediation. It is believed the split may have been from one of the sump samples. This is supported by the results of the concrete core sampling of the tunnel, which was the structure removed for the unit. Sample results from the concrete cores, B1008101-CJ-FC-002-CV 0-1/2, B1008101-CJ-FC-003-CV 0-1/2, and Bl008101-CJ-FC-004-CV 0-1/2 were 16.0, 10.0, and 19.8 pCi/g for Cs-137. These were biased concrete core samples of the source of the remediation (concrete tunnel), which were removed and contained much less activity than NRC-CDR #4.

Conclusion Based upon the results of the review of the LACBWR and GEL laboratories, there are differences in the sample origination, preparation, as well as an intercomparison bias to account for lower concentrations of Cs-137 in LACBWR gamma spectroscopy measurements. However, the reporting methodology utilized by LACBWR for final dose is conservative when compared to GEL. In all instances, the conclusion of release of the site is met.

RAI-7e - Path Forward: Provide data for the onsite measurements from the continuing characterization activities in the RPGPA Excavation (Survey Unit Ll-SUB-TDS B). In addition, provide the GEL Laboratories analytical reports for those survey units where they were not already provided (see RAI-3 for additional information).

RAI-7e - LaCrosseSolutions Response: See LaCrosseSolutions' response to RAI-3a.

RAI-8a - Path Forward: For the release records discussed in these RAls, explain the reason for the error( s).

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LaCrosseSolutions LC-2020-0023 RAI-8a - LaCrosseSolutions Response: The following are the explanations of errors in the release records in the order presented in the RAI:

1. Transposition error from the data assessment spreadsheet into the release record. The median and minimum values should be 0.00 dpm/100 cm2 *
2. Transposition error from the data assessment spreadsheet into the release record. The minimum and maximum columns are switched.
3. Judgmental samples were not an L TP requirement when this FSS was performed. As such, the survey design did not include them, and none were collected during FSS.
4. Copy and paste error from template release record. Section 8 should discuss the 4 QC replicate measurements collected (B2-010-102-FQFC-D05-BD, B2-010-102-FQRO-A07-BD, B2-010-102-FQRO-C10-BD, and B2-010-102-FQWM-Bl2-BD).
5. Copy and paste error. Correct number of QC measurements discussed in Section 6 should be 13.
6. Human error in formatting.
7. Many class 3 survey units utilized the more restrictive alarm set point of background plus MDCRsurveyor.
8. Transposition error from the data assessment spreadsheet into the release record.

When carrying over the table from the data assessment spreadsheet, the note was missed.

9. Several factors contribute to concentrations that exceed MDC that may be lower than concentrations that do not exceed MDC for the same radionuclide. This is not an uncommon occurrence as MDCs can fluctuate with differences in detector efficiency, count times, and sample weight. Further, the gamma spectroscopy software makes a determination for a given radionuclide whether it is positively identified (i.e., above MDC) or not.

The errors in the release records for survey units S3-012-102 B, S3-012-109 B, Sl-011-102, S3-012-102 A, S2-011-101 A, S2-011-101 B, S2-011-103, S2-011-103 A, S2-011-103 B, B2-010-102, B2-010-103, B3-012-101, B3-12-102, B3-012-104, B3-012-109, and B3-012-103 were corrected through revision. The revised release records are included with this RAI response.

RAl-8b - Path Fonvard: Review future submittals for overall quality and editorial errors.

RAI-8b - LaCrosseSolutions Response: EnergySolutions will take the following actions to improve the quality of future FSS deliverables:

1. The LT/FSS Manager and Director of Radiological Site Closure will be the primary authors of Chapter 5 of the LTPs for all future ES projects to ensure the FSS requirements follow standard industry guidance (NUREG-1757, MARSSIM, etc.)

and in accordance with NRC guidance/requirements.

2. ES will divide final reports into smaller, more concise reports with fewer release records for ease ofNRC reviews.
3. The release record and final report review process will be modified to provide more detailed focus on both editorial and technical errors.
4. To promote the goals of readability and consistency when writing L TPs, survey unit release records, and FSS final reports, ES will follow the guidance provided in NUREG-1379, NRC Editorial Style Guide.

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LaCrosseSolutions LC-2020-0023 RAI-9a - Path Forward: Confirm that the boundaries of the survey units surrounding the Turbine Building, Turbine Office Building, lB Diesel Generator Building Grounds (Survey Unit L 1-010-102) share physical boundaries such that 100 percent of the soil area was scanned during FSS. Please provide a map showing how the survey boundaries relate to one another.

RAI-9a - LaCrosseSolutions Response: LaCrosseSolutions confirmed that the physical boundaries of survey unit L 1-010-102 and the adjacent survey units are shared, and as a Class 1 survey unit, 100% of the surface area was scanned. Figure 1-1 in each of the Phase 1 and Phase 3 Final Reports delineates the shared boundaries of land survey units.

Documents Provided with this Response Include the Following:

Release Records and Final Status Survey Final Reports Release Record- Survey Unit B 1-010-001 Release Record- Survey Unit Ll-SUB-TDS-A Release Record- Survey Unit B 1-010-004 Release Record- Survey Unit Ll-SUB-TDS-B Release Record- Survey Unit B2-010-101 Release Record- Survey Unit L 1-SUB-TDS Release Record- Survey Unit B2-010-102 Release Record- Survey Unit L2-011-101 Release Record- Survey Unit B2-010-103 Release Record- Survey Unit L2-011-104 Release Record- Survey Unit B3-012-101 Release Record- Survey Unit S 1-011-102 Release Record- Survey Unit B3-012-102 Release Record- Survey Unit S2-011-101 A Release Record- Survey Unit B3-012-103 Release Record- Survey Unit S2-011-101 B Release Record- Survey Unit B3-012-104 Release Record- Survey Unit S2-011-103 A Release Record- Survey Unit B3-012-109 Release Record- Survey Unit S2-011-103 B Release Record- Survey Unit Ll-010-101 C Release Record- Survey Unit S2-011-103 Release Record- Survey Unit L 1-010-101 Release Record- Survey Unit S3-012-102 A Release Record- Survey Unit Ll-010-104 Release Record- Survey Unit S3-012-102 B Release Record- Survey Unit Ll-010-105 Release Record- Survey Unit S3-012-109 B Release Record- Survey Unit Ll-010-106 FSSR Phase 2 Release Record- Survey Unit L 1-010-107 FSSRPhase 3 Release Record- Survey Unit Ll-SUB-CDR Spreadsheet LACBWR IC Dose Calculations Procedures and Technical Support Documents LC-RP-PR-060, Calibration and Initial Set-Up of the 2350-1 LC-FS-PR-018, Radiation Surveys of Pipe Interiors using Sodium/Cesium Iodide Detectors LC-FS-TSD-005, MCNP Modeling of Water Discharge Pipes for the LaCrosse Boiling Water Reactor LC-FS-TSD-003, Assessment of the LACBWR Circulating Water Discharge Pipe Final Status Survey Data for Detection Efficiency and Detector Background Page 26 of26

LaCrosseSolutions LS-2020-0023 Attachment 2 La Crosse Boiling Water Reactor Preflight Report for Enclosure to LC-2020-0023

LaCrosseSolutions LC-2020-0023 Attachment 2 - Preflight Report Page 1 of 5 This document serves as the preflight report for the enclosure to LaCrosseSolutions letter LC-2020-0023. The following files do not pass pre-flight criteria or do not meet NRC criteria; however, the text is word searchable and legible.

Preflight Document Name File Name Reason Status Lacrosse Boiling Water Reactor Document contains logos, digital photos, FINAL STATUS SURVEY FINAL REPORT- 01 - LACBWR FSS PHASE 2 FINAL REPORT Failed signatures, and scanned pages < 300 ppi, PHASE2 R.l clear and legible Revision 1, October 2020 Lacrosse Boiling Water Reactor Document contains logos, digital photos, FINAL STATUS SURVEY FINAL REPORT- 02 - LACBWR FSS PHASE 3 FINAL REPORT Failed signatures, and scanned pages< 300 ppi, PHASE3 R.l clear and legible Revision 1, October 2020 Appendices to the Final Status Survey Reports Document contains logos, digital photos, Reactor Building Basement B 1-010-004 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Survey Unit Bl-010-001, Revision 1 clear and legible Document contains logos, digital photos, Waste Gas Tank Vault Basement B 1-010-004 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Survey Unit B 1-010-004, Revision 1 clear and legible Document contains logos, digital photos, LACBWR Crib House B2-010-101 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Survey Unit B2-010-101, Revision 1 clear and legible Document contains logos, digital photos, Genoa 3 Crib House B2-010-102 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Survey Unit B2-010-102, Revision 1 clear and legible Document contains logos, digital photos, LACBWR Administration Building Survey Unit B2-010-103 Release Record R. l FINAL Failed signatures, and scanned pages< 300 ppi, B2-010-103, Revision 1 clear and legible

LaCrosseSolutions LC-2020-0023 Attachment 2 - Preflight Report Page 2 of 5 Preflight Document Name File Name Reason Status Document contains logos, digital photos, Back-Up Control Center B3-012-101 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Survey Unit B3-012-101, Revision 1 clear and legible Document contains logos, digital photos, Transmission Sub-Station Switch House Survey B3-012-102 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Unit B3-012-102, Revision 1 clear and legible Document contains logos, digital photos, Genoa 1 Crib House B3-012-103 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Survey Unit B3-012-103, Revision 1 clear and legible Document contains logos, digital photos, Barge Wash Break Room B3-012-104 Release Record R.1 FINAL Failed signatures, and scanned pages < 300 ppi, Survey Unit B3-012-104, Revision 1 clear and legible Document contains logos, digital photos, Security Station B3-012-109 Release Record R.1 FINAL Failed signatures, and scanned pages < 300 ppi, Survey Unit B3-012-109, Revision I clear and legible Document contains logos, digital photos, Waste Treatment Building Excavation Survey L 1-010-101 C Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Unit Ll.,.010-l0lC, Revision 1 clear and legible Survey Unit Ll-010-101 Document contains logos, digital photos, Reactor Building, WTB, WGTV, Ventilation Ll-010-101 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Stack Grounds, Revision 1 clear and legible Document contains logos, digital photos, Survey Unit Ll-010-104 North LSE Grounds, Ll-010-104 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Revision 1 clear and legible Document contains logos, digital photos, Survey Unit Ll-010-105 North Interim Debris Ll-010-105 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Storage Area, Revision 1 clear and legible

LaCrosseSolutions LC-2020-0023 Attachment 2 - Preflight Report Page 3 of 5 Preflight Document Name File Name Reason Status Document contains logos, digital photos, Survey Unit Ll-010-106 North Loading Area, Ll-010-106 Release Record R. 1 FINAL Failed signatures, and scanned pages< 300 ppi, Revision 1 clear and legible Document contains logos, digital photos, Survey Unit Ll-010-107 Outside East LSE Area, Ll-010-107 Release Record R. 1 FINAL Failed signatures, and scanned pages < 300 ppi, Revision 1 clear and legible Document contains logos, digital photos, Survey Unit Ll-Sub-CDR Stack, Pipe Tunnel, Ll-SUB-CDR Release Record R.l FINAL Failed signatures, and scanned pages< 300 ppi, RPGP A Excavation, Revision I clear and legible Survey Unit Ll-SUB-TDS A Document contains logos, digital photos, Eastern Portion TB, Sump, Pit, Diesel, L 1-SUB-TDS A Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Revision 1 clear and legible Survey Unit Ll-SUB-TDS B RPGPA, Document contains logos, digital photos, Ll-SUB-TDS B Release Record R.l FINAL Failed signatures, and scanned pages< 300 ppi, Revisions 1 clear and legible Document contains logos, digital photos, Survey Unit Ll-Sub-TDS, Revision 1 Ll-SUB-TDS Release Record R. l FINAL Failed signatures, and scanned pages< 300 ppi, clear and legible Survey Unit L2-01 l-101 Area North ofLSE Document contains logos, digital photos, L2-011-101 Release Record R.1 FINAL Failed signatures, and scanned pages < 300 ppi, Fence, Revision 1 clear and legible Survey Unit L2-0l l-104 G3 Crib House, Circ. Document contains logos, digital photos, L2-011-104 Release Record R. l FINAL Failed signatures, and scanned pages < 300 ppi, Water Discharge Land, Revision 1 clear and legible Document contains logos, digital photos, Circulating Water Discharge Pipe S 1-011-102 Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Survey Unit Sl-011-102, Revision 1 clear and legible

LaCrosseSolutions LC-2020-0023 Attachment 2 - Preflight Report Page 4 of 5 Preflight Document Name File Name Reason Status Document contains logos, digital photos, Storm Drain 3 Survey Unit S2-011-101 A, S2-011-101 A Release Record R.1 FINAL Failed signatures, and scanned pages < 300 ppi, Revision 1 clear and legible Document contains logos, digital photos, Storm Drain 6 Survey Unit S2-011-101 B, S2-011-101 B Release Record R.1 FINAL Failed signatures, and scanned pages < 300 ppi, Revision 1 clear and legible Document contains logos, digital photos, De-Icing Line Survey Unit S2-0l 1-103 A, S2-011-103 A Release Record R.1 FINAL Failed signatures, and scanned pages < 300 ppi, Revision 1 clear and legible Document contains logos, digital photos, Low Pressure Service Water S2-011-103 B Release Record R. l FINAL Failed signatures, and scanned pages< 300 ppi, Survey Unit S2-0l l-103 B, Revision 1 clear and legible Document contains logos, digital photos, Circulating Water Intake Pipe S2-0l l-103 Release Record R.1 FINAL Failed signatures, and scanned pages < 300 ppi, Survey Unit S2-011-103, Revision 1 clear and legible Document contains logos, digital photos, Storm Drain 4 Survey Unit S3-012-102 A, S3-012-102 A Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Revision 1 clear and legible Document contains logos, digital photos, Storm Drain 5 Survey Unit S3-012-102 B, S3-012-102 B Release Record R.1 FINAL Failed signatures, and scanned pages< 300 ppi, Revision l clear and legible Document contains logos, digital photos, Storm Drain 2 Survey Unit S3-012-109 B, S3-012-109 B Release Record R.1 FINAL Failed signatures, and scanned pages < 300 ppi, Revision 1 clear and legible

LaCrosseSolutions LC-2020-0023 Attachment 2 - Preflight Report Page 5 of 5 Preflight Document Name File Name Reason Status Supporting Procedures Document contains logos, digital photos, Radiation Surveys of Pipe Interiors Using LC-FS-PR-018 Failed signatures, and scanned pages< 300 ppi, Sodium/Cesium Iodide Detectors clear and legible Assessment of the LACBWR Circulating Water Document contains logos, digital photos, Discharge Pipe Final Status Survey Data for LC-FS-TSD-003 Failed signatures, and scanned pages< 300 ppi, Detection Efficiency and Detector Background clear and legible Document contains logos, digital photos, MCNP Modelling of Water Discharge Pipes for LC-FS-TSD-005 Failed signatures, and scanned pages< 300 ppi, the Lacrosse Boiling Water Reactor clear and legible Document contains logos, digital photos, Calibration and Initial Set-Up of The 2350-1 LC-RP-PR-060 Failed signatures, and scanned pages< 300 ppi, clear and legible Dose Calculations (Excel file)

LACBWR IC Dose Calculations LACBWR IC Dose Calculations NIA NIA

LaCrosseSolutions LS-2020-0023 Enclosure La Crosse Boiling Water Reactor CD containing Revised Final Status Survey Final Reports and Related Release Records, and the LACBWR IC *>>ose Calculations as Referenced in the Response to the Request for Additional Information

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