ML22033A163

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License Termination Plan Chapter 3, Revision 3, Identification of Remaining Site Dismantlement Activities
ML22033A163
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 01/26/2022
From:
LaCrosseSolutions
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML22033A165 List:
References
LS-2022-0002
Download: ML22033A163 (19)


Text

LA CROSSE BOILING WATER REACTOR LICENSE TERMINATION PLAN CHAPTER 3, REVISION 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-i TABLE OF CONTENTS

3.

Identification of Remaining Site Dismantlement Activities................................................ 3-1 3.1.

Introduction................................................................................................................... 3-1 3.2.

Completed and Ongoing Decommissioning Activities and Tasks................................ 3-3 3.2.1.

Overview................................................................................................................ 3-3 3.2.2.

Dismantlement of Systems and Components........................................................ 3-4 3.2.3.

Dismantlement of Reactor Building...................................................................... 3-4 3.2.4.

Turbine Building and Turbine Office Building..................................................... 3-5 3.2.5.

Waste Treatment Building, Gas Storage Tank Vault and LSA Storage Building. 3-6 3.2.6.

LACBWR Crib House........................................................................................... 3-8 3.2.7.

Maintenance Eat Shack and 1B Diesel Generator Building.................................. 3-8 3.2.8.

Ventilation Stack.................................................................................................... 3-8 3.2.9.

Additional Activities.............................................................................................. 3-9 3.3.

Future Decommissioning Activities and Tasks............................................................. 3-9 3.4.

Radiological Impacts of Decommissioning Activities................................................ 3-10 3.4.1.

Control Mechanisms to Mitigate the Recontamination of Remediated Areas..... 3-10 3.4.2.

Occupational Exposure........................................................................................ 3-11 3.4.3.

Exposure to the Public......................................................................................... 3-12 3.4.4.

Radioactive Waste Projections............................................................................ 3-12 3.4.5.

Project Milestones................................................................................................ 3-14 3.5.

References................................................................................................................... 3-15 LIST OF TABLES Table 3-1 Status of Major LACBWR Systems and Components as of November 2021....... 3-2 Table 3-2 Radiation Exposure Actuals and Projections (in person REM)........................... 3-12 Table 3-3 Projected Waste Quantities.................................................................................. 3-13 Table 3-4 General Project Milestones.................................................................................. 3-14

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-ii LIST OF ACRONYMS AND ABBREVIATIONS ALARA As Low As Reasonably Achievable ACM Asbestos Containing Material AMSL Above Mean Sea Level BSFR Bulk Survey For Release CCW Component Cooling Water CST Condensate Storage Tank D-Plan/PSDAR Decommissioning Plan/Post Shutdown Decommissioning Activities Report FESW Fuel Element Storage Well FSS Final Status Survey G-3 Genoa Fossil Station HPSW High Pressure Service Water HVAC Heating Ventilation Air Conditioning kVA kilo-Volt-Ampere ISFSI Independent Spent Fuel Storage Installation LACBWR La Crosse Boiling Water Reactor LPSW Low Pressure Service Water LSA Low Specific Activity LSE LACBWR Site Enclosure LTP License Termination Plan NRC Nuclear Regulatory Commission ODCM Off-site Dose Calculation Manual OHST Overhead Storage Tank REMP Radiological Environmental Monitoring Program RPV Reactor Pressure Vessel RWP Radiation Work Permit WGTV Waste Gas Tank Vault WTB Waste Treatment Building

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-iii Page Intentionally Left Blank

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-1

3. Identification of Remaining Site Dismantlement Activities 3.1. Introduction In accordance with 10CFR50.82 (a)(9)(ii)(B), the License Termination Plan (LTP) must identify the remaining major dismantlement and decontamination activities for the decommissioning at the time of submittal. The information includes those areas and equipment that need further remediation and an assessment of the potential radiological conditions that may be encountered.

Estimates of the occupational radiation dose and the quantity of radioactive material to be released to unrestricted areas during the completion of the scheduled tasks are provided. The projected volumes of radioactive waste that will be generated are also included. These activities will be undertaken pursuant to the current 10 CFR 50 license, are consistent with the La Crosse Boiling Water Reactor (LACBWR) Decommissioning Plan and Post-Shutdown Decommissioning Activities Report (D-Plan/PSDAR) (1) and do not depend upon LTP approval to proceed.

The LACBWR site has been decontaminated and dismantled in accordance with the DECON alternative, as described in NUREG-0586 Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Volume 1 (2). Completion of the DECON alternative is contingent upon continued access to one or more low level waste disposal sites.

Currently, LaCrosseSolutions (Solutions) has access to low-level waste disposal facilities located in Andrews, Texas and at the EnergySolutions facility located in Clive, Utah.

Decommissioning activities were coordinated with the applicable Federal and State regulatory agencies in accordance with plant administrative procedures. Applicable Federal, State and local regulatory agencies are listed in section 8.7.2 of LTP Chapter 8.

Decommissioning activities at LACBWR were conducted in accordance with the requirements of 10 CFR 50.82(a)(6) and (a)(7). At the time of LTP submittal, the remaining activities did not involve any un-reviewed safety questions or changes in the Technical Specifications for LACBWR. If an activity requires prior NRC approval under 10 CFR 50.59(c)(2), or a change to the technical specifications or license, a submittal will be made to the NRC for review and approval before implementing the activity in question.

Decommissioning activities were conducted under the Solutions Radiation Protection Program, Safety and Health Program, and Waste Management Program. Activities conducted during decommissioning do not pose any greater radiological or safety risk than those conducted during operations, especially those during major maintenance and outage evolutions.

Section 3.2 describes the decontamination and dismantlement activities that were performed.

Table 3-1 contains a list of major systems and components that have been removed.

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-2 Table 3-1 Status of Major LACBWR Systems and Components as of November 2021 System or Component Status Forced Circulation System Removed Reactor Vessel Internals Removed Reactor Vessel Removed Main Steam in Reactor Bldg.

Removed Decay Heat Cooling System Removed Primary Purification System Removed Feedwater in Reactor Bldg.

Removed Seal Injection System Removed Alternate Core Spray System Removed Gaseous Waste Disposal System Removed Fuel Element Storage Well System Removed Component Cooling Water (CCW)

Removed Hydraulic Valve Accumulator System Removed Well Water System Removed Demineralized Water System Removed Overhead Storage Tank (OHST)

Removed Station and Control Air System Removed Low Pressure Service Water Removed High Pressure Service Water Removed; portion from LACBWR Crib House to G3 remains operational Circulating Water System Remains in place - pumps de-energized Condensate and Feedwater Tanks and Heaters Removed Steam Turbine Removed 60-Megawatt Generator Removed Main Condenser & Accessories Removed

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-3 Table 3-1 (continued) Status of Major LACBWR Systems and Components as of November 2021 System or Component Status Turbine Bldg. Main Steam Removed Turbine Bldg. Condensate and Feed Removed Turbine Oil and Hydrogen Seal Oil Removed Liquid Waste Collection Systems Removed Fuel Transfer Bridge Removed HVAC Systems Removed Electrical Systems Removed Asbestos Abatement Complete After the balance of the site is remediated and the levels of residual radioactivity are demonstrated to be below the unrestricted release criteria, the 10 CFR Part 50 license will be reduced to the area around the Independent Spent Fuel Storage Installation (ISFSI) and the site will be transferred back to Dairyland under the 10 CFR Part 50 license. Spent fuel and decommissioning activities completed to date are provided in section 3.2.

3.2. Completed and Ongoing Decommissioning Activities and Tasks 3.2.1. Overview Solutions and its subcontractors have completed all decommissioning and demolition activities, as of November 2021. In excess of 6 million pounds of metallic waste have been removed, shipped, and disposed of in addition to the Reactor Pressure Vessel (RPV) and spent fuel storage racks.

Removal and disposal of the RPV included disposition of irradiated hardware and all other Class B and C waste.

Waste stored in the Fuel Element Storage Well (FESW) was processed and collected with other Class B/C waste (i.e., resins, filters, and waste barrel contents) and packaged in three liners that were shipped for disposal in June 2007. The RPV containing the reactor internals and 29 control rod blades was filled with low-density cellular concrete with the reactor head installed.

Attachments to the RPV were removed and all other appurtenances were cut. The RPV was removed from the Reactor Building and was shipped for disposal in June 2007. After all spent fuel assemblies and fuel debris were placed in dry cask storage in the ISFSI in September 2012, the storage racks and installed components were removed from the FESW.

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-4 3.2.2. Dismantlement of Systems and Components All systems have been removed and disposed of with the exception of the following buried piping systems, which successfully underwent FSS and were abandoned in place:

  • Circulating Water Discharge
  • De-Icing Line
  • Circulating Water Intake
  • Storm Drain (six runs) 3.2.3. Dismantlement of Reactor Building Demolition of the Reactor Building was completed on May 23, 2019. The Reactor Building was a right circular cylinder building with a hemispherical dome and semi-ellipsoidal bottom. It had an overall internal height of 144 feet and an inside diameter of 60 feet, and it extended 26 feet 6 inches below grade level. The steel shell thickness was 1.16 inch, except for the upper hemispherical dome, which was 0.60 inch thick.

The building contained most of the equipment associated with the nuclear steam supply system, including the RPV and biological shielding. The interior of the shell was lined with a 9-inch-thick layer of concrete to an elevation of 727 feet 10 inches Above Mean Sea Level (AMSL). The structure was supported on a foundation consisting of concrete-steel piles and a pile capping of concrete approximately 3 feet thick.

The shell included two airlocks. The personnel airlock connected the Reactor Building to the Turbine Building. In addition, there was also 8 feet by 10 feet freight door opening in the Reactor Building that was intended to accommodate large pieces of equipment. To facilitate RPV removal and dry cask storage, an opening was created in the Reactor Building. The opening was closed by a weather tight, insulated, roll-up, bi-parting door. The majority of pipe penetrations exited the Reactor Building 1 to 10 feet below grade level either at the northwest quadrant or at the northeast quadrant and entered the pipe tunnel.

A 50-ton traveling polar crane with a 5 ton auxiliary hoist was located in the upper part of the Reactor Building. The bridge completely spanned the building and traveled on circular tracks supported by columns around the inside of the building. The lifting cables of both the 50-ton and the 5-ton hoists were also long enough to reach down through hatchways into the basement area.

Hatches at several positions in the main and intermediate floors could have been opened to allow passage of the cables and equipment.

The remaining components and systems in the Reactor Building were drained, dismantled, and removed. Area preparation and set-up for commodity removal included radiological surveys and the identification and mitigation of any hazardous material.

Systems or components were removed utilizing mechanical means with support from the overhead crane or local hoists. Some systems or components required hot work activities to size reduce.

The systems were loaded into shipping containers.

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-5 The OHST tank was been dewatered and de-sludged. The tank was adequately characterized and a fixative applied in preparation for building demolition. Keeping associated piping and components in place while performing this activity allowed for the collection of any liquids. This piping was dismantled and removed once the tank was prepared for demolition.

In preparation for the building demolition, an enclosure was erected on the face of the Reactor Building around the roll up doors that were installed to remove the reactor vessel. The engineered enclosure was approximately 80 feet by 80 feet by 90 feet. The enclosure was equipped with an HEPA ventilation system and a vestibule to allow waste containers to be loaded and removed from inside the enclosure.

Solutions utilized excavators with proper attachments to demolish and size-reduce all interior structures, components and concrete from within the enclosure. All system, components and concrete were removed from the steel liner and loaded out through the Reactor Building Containment Tent and Waste Transfer Cell. The thermal shield was segmented using a hydraulic hammer into manageable pieces for special packaging as mixed waste.

Following the completion of Contamination Verification Surveys (CVS), the Reactor Containment Tent and Waste Transfer Cell were mechanically demolished utilizing excavators with appropriate attachments. The Reactor Building Liner was demolished utilizing a combination of thermal cutting and mechanical methods.

After commodity and steel liner removal was completed, a radiological assessment was performed on the exposed concrete to ensure that any individual ISOCS measurement would not exceed the Operational DCGL during Final Status Survey (FSS) (see section 5.4.1). If unacceptable contamination was identified, then decontamination activities were conducted until levels were met. The remaining structural concrete below the 636-foot elevation (i.e., concrete bowl below 636-foot elevation, concrete pile cap and piles) remained and was subjected to an FSS in accordance with LTP Chapter 5 Demolition debris resulting from the demolition within the Reactor Building was treated as low-level radioactive waste, loaded into appropriate containers and trucked to a rail trans-load facility in Winona, MN where the waste container was transferred to a rail car and then shipped to the EnergySolutions disposal site in Clive, Utah.

3.2.4. Turbine Building and Turbine Office Building Demolition of the Turbine Building was completed on February 28, 2018. The Turbine Building housed the steam turbine and generator, main condenser, electrical switchgear, and other pneumatic, mechanical and hydraulic systems and equipment. A 30-ton traveling bridge crane with a 5-ton auxiliary hoist capacity spanned the Turbine Building. The crane had access to major equipment items located below the floor through numerous hatches in the main floor. The Turbine Building was 105 feet by 79 feet and 60 feet tall.

The Turbine Office Building contained offices, the Control Room, locker room facilities, laboratory, shops, counting room, personnel change room, decontamination facilities, heating, ventilating and air conditioning equipment, rest rooms, storeroom, and space for other plant services. In general, these areas were separated from power plant equipment spaces. The Turbine Office Building was 110 feet by 50 feet and 45 feet tall.

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-6 Commodity removal was completed in the Turbine Building utilizing cutting tools and mechanical means to dismantle radioactive piping and components. Band saws and reciprocating saws were the primary methods used. System pieces and waste was sized to meet packaging and waste disposal criteria. Waste was packaged and stored in the waste loading area located on the ground floor in the northwest corner of the Turbine Building until it was properly shipped and disposed of at an off-site facility.

After the radioactive commodity removal was complete, surveys were performed of all remaining systems, components and structural surfaces to ensure that the open-air demolition criteria specified in Reference 3 was met. Structural materials that did not meet the open-air demolition criteria were removed, segregated, properly packaged and disposed of as radioactive waste. All radioactive waste was loaded and transported to an acceptable radioactive waste disposal facility, primarily the EnergySolutions facility in Clive, Utah. All structural decontamination activities were performed in accordance with approved Radiation Work Permits (RWP) and under the oversight of Radiation Protection personnel.

All remaining systems and components, interior structural surfaces and structural concrete have been demolished to the ground level slab. The general demolition sequence within the Turbine Building was performed from the top down and from west to east to allow open access to load out areas. Concrete was processed to meet disposal site requirements. Misting methods were utilized during building demolition to minimize dust. The majority of the construction debris resulting from the demolition of the structure was treated as low level radioactive waste and was shipped to the licensed radioactive waste disposal facility. Waste was loaded into appropriate containers and trucked to a rail trans-load facility in Winona, MN where the waste container was transferred to a rail car and then shipped to the EnergySolutions disposal site in Clive, Utah. If possible, some materials including structural concrete were radiologically surveyed and released for unrestricted use in accordance with NUREG-1575, Supplement 1, Multi-Agency Radiation Survey and Assessment of Materials and Equipment Manual (MARSAME) (3). Surveys were performed in accordance with the site procedure for the unconditional release of materials to verify that the material was free of plant-derived radioactive material. Materials released for unconditional use were recycled or released for disposal at a non-radiological landfill. No recycled materials remained on site. All bulk material sent for recycle or disposal at a non-radioactive disposal site was subjected to a final assessment for the presence of any residual radioactive contamination by undergoing an aggregate survey by use of a Ludlum Model 193-6 Micro R instrument or similar.

When the Turbine Building was demolished, the foundation slab was exposed. An excavator with appropriate tools (pneumatic hammer, loading bucket, etc.) was used to remove the building slab and foundation to meet disposal site requirements. During slab and foundation removal, underground utilities were also removed, surveyed, packaged and properly disposed. Some examples of underground utilities might be gas, water, miscellaneous piping, and discharge line.

The slab and foundation walls were removed to a minimum depth of 3 feet below grade (636 foot elevation).

3.2.5. Waste Treatment Building, Gas Storage Tank Vault and LSA Storage Building The WTB was demolished on August 11, 2017. The WTB was located to the northeast of the Reactor Building. The building contained facilities and equipment for decontamination and the

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-7 collection, processing, storage, and disposal of low level solid radioactive waste. The WTB was 34 feet by 42 feet and 20 feet tall. The WTB basement floor was at elevation 630 feet and had a 3-foot-deep sump, with 8-inch-thick walls and a bottom which extended to a depth of 626 feet.

The grade floor of the WTB contained a shielded compartment which housed a 320 ft3 stainless steel spent resin receiving tank and resin receiving and transfer equipment. Located outside of the shielded cubicle were two back-washable radioactive liquid waste filters and dewatering piping, containers, and pumps. The main floor of the WTB also housed a decontamination facility, consisting of a steam cleaning booth, a decontamination sink, and heating/ventilation/air conditioning units.

The basement of the WTB consisted of two shielded cubicles. One cubicle, to which access was gained by removal of floor shield plugs, was used for the storage of high activity solid waste drums.

The other area, to which access was gained by a stairway, contained the dewatering ion exchanger, the WTB sump and pump, and additional waste storage space. The WTB was demolished and removed in its entirety.

The Waste Gas Tank Vault (WGTV) was a 29 foot by 31-foot underground concrete structure with 14 feet high walls and 2 feet thick floors, walls, and a ceiling located below ground just outside of the WTB. The vault was 3 feet below grade with a sump that extended to a depth of 22 feet or elevation 617 feet. The Gas Decay System routed main condenser gases through various components for drying, filtering, recombining, monitoring and holdup for decay. Two 1,600 cubic feet tanks were located in the GSTV. The tanks had the capability to store radioactive gases until such time that they were batch released via the stack. The tanks and associated piping were removed in preparation for FSS.

The Low Specific Activity (LSA) Storage Building was located southwest of the Turbine Building.

It was used to store processed, packaged and sealed low level dry active waste materials, and sealed low level activity components. No liquid wastes were stored in this building. The LSA Building was 27 feet by 80 feet and 15 feet tall.

Commodity removal has been completed in the WTB, WGTV and LSA Building utilizing cutting tools and mechanical means to dismantle radioactive piping and components. Band saws and reciprocating saws were the primary methods used. The interiors of tanks were cleaned and a fixative was applied prior to dismantlement. System pieces and waste was sized to meet packaging and waste disposal criteria.

After commodity removal was complete, the interior concrete surfaces were remediated to the open-air demolition criteria per Reference 3. Structural material that did not meet the open-air demolition criteria was removed, segregated, packaged and disposed of as radioactive waste. All radioactive waste was loaded into appropriate containers and transported to an acceptable radioactive waste disposal facility.

When all structural surfaces were decontaminated to the open-air demolition criteria, the above grade portions of each building were demolished. The entire LSA building, including the concrete floor slab was removed. The remaining structural concrete for the WTB and GSTV located below 636 foot elevation has remained and was subjected to an FSS in accordance with Chapter 5.

Concrete was processed to meet disposal site requirements as radioactive waste. Misting methods were utilized during building demolition to minimize dust. All construction debris resulting from

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-8 the demolition of each of the structure was treated as low-level radioactive waste and was shipped to the licensed radioactive waste disposal facility. Waste was loaded into appropriate containers and trucked to a rail trans-load facility in Winona, MN where the waste container was transferred to a rail car and then shipped to the EnergySolutions disposal site in Clive, Utah.

3.2.6. LACBWR Crib House The LACBWR Crib House is located on the bank of the Mississippi River to the west of the plant.

The structure served as the intake for the Circulating Water System, which provided cooling water to various LACBWR plant systems. The LACBWR Crib House contains the diesel-driven high pressure service water pumps, low pressure service water pumps and the circulating water pumps.

The LACBWR Crib House is 35 feet by 45 feet and 15 feet tall.

In addition to the G-3 Crib House, the LACBWR Crib House also currently serves the active G-3 facility, and consequently, will remain intact and undisturbed by the decommissioning process.

An FSS was performed on the interior and exterior structural surface and systems of the LACBWR Crib House in accordance with Chapter 5.

3.2.7. Maintenance Eat Shack and 1B Diesel Generator Building The Maintenance Eat Shack was 20 feet by 40 feet and 15 feet tall steel-sided building with windows constructed over a concrete slab.

The 1B Diesel Generator Building was attached to the southeast corner of the Turbine Building and contained the Electrical Equipment Room, Diesel Generator Room, and an empty Battery Room. The building was constructed of concrete block and steel beams and braces. The building was L-shaped having largest dimensions of 31 feet by 38 feet and 13 feet tall.

These two structures have been radiologically characterized and completely demolished down to grade. The foundations were removed at a later date. Construction debris resulting from the demolition of these structures was treated as low-level radioactive waste and was shipped to the licensed radioactive waste disposal facility. Waste was loaded into appropriate containers and trucked to a rail trans-load facility in Winona, MN where the waste container was transferred to a rail car and then shipped to the EnergySolutions disposal site in Clive, Utah. Some materials, including structural concrete was radiologically surveyed and released for unconditional release from site. Surveys were performed in accordance with the site procedure for the unconditional release of materials to verify that the material is free of plant-derived radioactive material.

Materials released for unconditional were recycled or released for disposal at a non-radiological landfill. No recycled materials remain on site. All bulk material sent for recycle or disposal at a non-radioactive disposal site were subjected to a final assessment for the presence of any residual radioactive contamination by undergoing an aggregate survey by use of a Ludlum Model 193-6 Micro R instrument or similar.

3.2.8. Ventilation Stack The LACBWR Ventilation Stack was 350 feet high, tapered, reinforced concrete structure with an outside diameter of 7 feet at the top and 25 feet at the base. The wall thickness varied from 15 inches at the bottom to 6 inches at the top. The 4 feet thick foundation mat rested on a pile

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-9 cluster of 78 piles. The foundation mat was a 40-foot square concrete base formed without triangular sides on the southeast and southwest corners.

The Ventilation Stack was radiologically characterized and then completely demolished. Once characterization was complete, interior concrete surfaces were remediated to open air demolition criteria per Reference 3 and demolished. A fixative was applied to the interior surfaces to mitigate any loose contamination.

Demolition was performed from the top down. A traveling scaffold system was employed to provide access to the exterior of the stack. The stack was removed using mechanical hand tools down to the lower 40-foot elevation. The bottom 40 feet of the ventilation stack was removed with excavators and pneumatic breakers. The excavators were used to saw and break the concrete into manageable sections and drop the sections into the interior of stack. An opening at the bottom of the stack was made to allow the removal of the concrete debris. The concrete foundation mat was removed in its entirety. Wet methods were utilized during all demolition to minimize dust.

Project personal monitored and barricaded the fall zones in the vicinity of the ventilation stack.

All construction debris resulting from the demolition of these structures was treated as low-level radioactive waste and was shipped to the licensed radioactive waste disposal facility. Waste was loaded into appropriate containers and trucked to a rail trans-load facility in Winona, MN where the waste container was transferred to a rail car and then shipped to the EnergySolutions disposal site in Clive, Utah.

3.2.9. Additional Activities Other completed decommissioning activities include:

The abatement, packaging and disposal of known and readily accessible lead and/or lead containing material.

The abatement, packaging and disposal of known and readily accessible Asbestos Containing Material (ACM).

The placement of all spent fuel into dry storage in the ISFSI facility and the removal of fuel racks from the FESW.

The disconnection of LACBWR from off-site electrical power and placing LACBWR in a Cold and Dark status.

The draining and removal of other miscellaneous system piping.

3.3. Future Decommissioning Activities and Tasks Solutions expects the 10 CFR Part 50 license to be reduced to the area around the ISFSI during the first quarter of 2022. After the partial site release the site will be transferred back to Dairyland under the 10 CFR Part 50 license. It is expected that the ISFSI and surrounding environs will be decommissioned in the distant future.

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-10 3.4. Radiological Impacts of Decommissioning Activities The decommissioning activities described are and will be conducted under the provisions of the Solutions Radiation Protection Program and Radioactive Waste Management Program. These programs are and will continue to be implemented as described in the D-Plan/PSDAR. The Solutions Radiation Protection Program and written site procedures are intended to provide sufficient information to demonstrate that decommissioning activities will be performed in accordance with 10 CFR 19, Notices, Instructions And Reports To Workers, 10 CFR 20, Standards For Protection Against Radiation and to maintain radiation exposures As Low As Reasonably Achievable (ALARA) The Solutions Radioactive Waste Management Program controls the generation, characterization, processing, handling, shipping, and disposal of radioactive waste in accordance with the approved Solutions Radiation Protection Program, and written plant procedures.

The current Radiation Protection Program, Waste Management Program, and Radiological Effluent Monitoring and Radiological Effluent Monitoring and Offsite Dose Calculation Manual (ODCM) (4) will be used to protect the workers and the public, as applicable, during the various decontamination and decommissioning activities. These well-established programs are routinely inspected by the Nuclear Regulatory Commission (NRC) to ensure that workers, the public, and the environment are protected during facility decommissioning activities. It is also important to note that decommissioning activities involve the same radiation protection and waste management considerations as those encountered during plant operations, maintenance and outages, and decommissioning activities conducted to date. There are no additional procedures for which approval is being sought in this LTP. As described in the D-Plan/PSDAR, the decommissioning will be accomplished with no significant adverse environmental impacts in that:

No site-specific factors pertaining to the decommissioning of the LACBWR would alter the conclusions presented in NUREG-0586 (see LTP Chapter 8).

Radiation dose to the public will be minimal.

Decommissioning is not an imminent health or safety concern and will generally have a positive environmental impact.

Continued application of the current and future Radiation Protection and Radiological Effluent Monitoring Programs at LACBWR ensures public protection in accordance with 10 CFR 20 and 10 CFR 50, Appendix I. Radiological Environmental Monitoring Program (REMP) reports for LACBWR to date conclude that the public exposure as a result of decommissioning activities is bounded by the evaluation in NUREG-0586, which concludes the impact is minimal.

All LACBWR site required environmental monitoring, other than for the LACBWR ISFSI, was terminated as of October 2019. The termination of environmental monitoring followed completion of both the final status surveys field work and independent verification survey field work by ORAU of the radiologically restricted area.

3.4.1. Control Mechanisms to Mitigate the Recontamination of Remediated Areas Due to the large scope of remaining structures and systems that will be decontaminated and dismantled, FSS of areas were performed in parallel with decommissioning activities.

Consequently, a systematic approach was employed to ensure that areas are adequately

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-11 remediated prior to performing FSS and ongoing decommissioning activities do not impact the radiological condition of areas, where compliance with the unrestricted release criteria as specified in 10 CFR 20.1402 has been demonstrated. These measures and mechanisms are described in LTP Chapter 5.

3.4.2. Occupational Exposure Table 3-2 provides the cumulative site dose estimates for the decommissioning of LACBWR.

This dose estimate is based on actual dose expenditures in Calendar Years 2016 through 2020, with estimated doses for 2021 and 2022. The total radiation exposure estimates for all decommissioning activities to complete the decommissioning schedule is estimated to be approximately 10.97 person-rem.

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-12 Table 3-2 Radiation Exposure Actuals and Projections (in person REM)

Activity 2016/2017 (actual) 2018 (actual) 2019 (actual) 2020 (actual) 2021/2022 (estimate)

Total Asbestos/Hazardous Material Abatement 2.67 2.67 Reactor Building 6.82 0.63 7.45 Waste Treatment Building 0.29 0.29 Turbine Building 0.07 0.07 Waste Processing 0.19 0.19 Remaining Structures 0.30 0.30 Totals 10.34 0.63 0.00 0.00 0.00 10.97 3.4.3. Exposure to the Public Continued application of Solutions Radiation Protection, Radioactive Waste, Radiological Effluent Technical Specification and Radiological Environmental Monitoring Program assures public protection in accordance with 10 CFR 20 and 10 CFR 50, Appendix I.

3.4.4. Radioactive Waste Projections The Radioactive Waste Management Program was used to control the characterization, generation, processing, handling, shipping, and disposal of radioactive waste during decommissioning.

Activated and contaminated systems, structures, and components represent the largest volume of low-level radioactive waste expected to be generated during decommissioning. Other forms of waste generated during decommissioning include:

Contaminated water; Used disposable protective clothing; Expended abrasive and absorbent materials; Expended resins and filters; Contamination control materials (e.g., strippable coatings, plastic enclosures); and Contaminated equipment used in the decommissioning process.

Table 3-3 provides projections of waste classifications and quantities that will be generated by the decommissioning of LACBWR. As Solutions has elected to use an approach commonly referred to as rip & ship verses performing significant on-site decontamination activities, the total volume of low-level radioactive waste for disposal has been estimated at 876,453 cubic feet. Actual waste volumes and classifications may vary. The vast majority of this waste was be shipped to the licensed EnergySolutions radioactive waste disposal facility in Clive, Utah.

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-13 Table 3-3 Projected Waste Quantities WASTE TYPE WASTE CLASS WASTE WEIGHT (lbs.)

PACKING DENSITY (lb./ft3)

WASTE VOLUME (ft3)

Debris: Concrete A

39,773,388 85 498,900 Debris: Rebar A

1,843,908 85 42,465 Debris: Metal A

3,630,540 30 151,070 Asphalt A

5,415,750 50 108,316 Soils A

2,8777,268 74 38,882 Asbestos A

300,776 17 17,693 Dry Active Waste (DAW)

A 30,880 12 2,574 Mixed Waste A

56,222 110 16,733 Clean Backfill -

(Debris to Landfill)

Clean Debris 0

0 Clean Asphalt Disposal Clean Debris 0

0 Recycle - Metals Scrap Metal 0

0 Recycle - Rebar Scrap Metal 0

0 Total Estimated Volume 876,453

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-14 3.4.5. Project Milestones Table 3-4 lists the current schedule for the remaining decommissioning activities.

Table 3-4 General Project Milestones Date Milestone Q2/2016 Submit LTP to NRC Q2/2016 License Transfer Complete Q3/2016 Mobilization Complete Q3/2017 Stack Demolition Complete Q1/2019 LTP Approval by NRC Q4/2018 Component Removal Complete Q1/2019 Building Demolition Complete Q2/2019 Transportation and Disposal Complete Q4/2019 Site Remediation Complete Q4/2019 FSS Complete Q2/2019 Site Restoration Complete Q4/2019 Submit Remaining FSS Reports and Request to Reduce Licensed Area to ISFSI Q2/2018 Submit License Transfer to Dairyland Amendment Request to NRC Q3/2019 extended to Q3/2022 License Transfer to Dairyland Approved by NRC Q2/2022 Request to Reduce Licensed Area to the ISFSI Approved by NRC Q2/2022 License Transfer to Dairyland Note:

Circumstances can change during decommissioning. If Solutions determines that the decommissioning cannot be completed as outlined in this schedule, Solutions will provide an updated schedule to the NRC.

La Crosse Boiling Water Reactor License Termination Plan Revision 3 3-15 3.5. References

1.

Dairyland Power Cooperative, LACBWR Decommissioning Plan and Post Shutdown Decommissioning Activities Report (D-Plan/PSDAR), Revision - March 2014.

2.

U.S. Nuclear Regulatory Commission NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Volume 1 -

November 2002.

3.

U.S. Nuclear Regulatory Commission NUREG-1575, Supplement 1, Multi-Agency Radiation Survey and Assessment of Materials and Equipment Manual (MARSAME) -

December 2006.

4.

Radiological Effluent Monitoring and Offsite Dose Calculation Manual (ODCM).