ML22069A128
| ML22069A128 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 03/08/2022 |
| From: | Van Noordennen G LaCrosseSolutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| LC-2022-0007 | |
| Download: ML22069A128 (25) | |
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LACROSSESOLUTIONS 10 CFR 50.36(a)(2)
March 8, 2022 LC-2022-0007 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 La Crosse Boiling Water Reactor Facility Operating License No. DPR-45 NRC Docket Nos. 50-409 and 72-046
Subject:
La Crosse Boiling Water Reactor (LACBWR) Annual Radiological Environmental Operating Report, Supplemental Letter In accordance with the Quality Assurance Program Description (QAPD), Appendix C, Section 2.5.1, "Annual Radiological Environmental Monitoring Report," and Section 2.5.2, "Annual Radioactive Effluent Release Report," the 2021 reports for Facility Operating License No. DPR-45 and the Independent Spent Fuel Storage Installation are required to be submitted prior to March 1. On February 28, 2022, LaCrosseSolutions notified the NRC that the shipment of environmental TLDs for the site were delayed due to supplier issues and that the reports would be submitted once the results were received. The purpose of this letter is to provide the 2021 Annual Radiological Environmental Operating Report, which includes the Radiological Environmental Monitoring Report and the Radioactive Efflu~nt Release Report.
There are no new regulatory commitments in this submittal.
If there are any questions regarding this report, please contact me at (860) 462-9707.
Respectfully, Gerard van '. , Digitally signed by Gerard van Noordennen
\. DN: cn=Gerard van Noordennen, o=EnergySolutions,
, * .ou=Regulatory Affairs,
~mail=gpvannoordennen@energysolutions.com, c=US Noordennen Date: 2022.03.08 14:39:32 -05'00' Gerard van N oordennen Senior Vice President Regulatory Affairs _:zFZ5 cc: Kimberly Conway, U.S. NRC Project Manager _:rEJ--1~
Regional Administrator, U.S. NRC, Region III La Crosse Boiling Water Reactor Service List f'JH 5 5 2- ?=,
- vH..55 S4601 State Highway 35, Genoa, WI 54632
Service List for La Crosse Boiling Water Reactor Ken Robuck Regional Administrator President and CEO U.S. NRC, Region III EnergySolutions 2443 Warrenville Road 299 South Main Street, Suite 1700 Lisle, IL 60532-4352 Salt Lake City, UT 84111 Paul Schmidt, Manager John Sauger Radiation Protection Section President and Chief Nuclear Officer Bureau of Environmental and Occupational Health ReactorD & D Division of Public Health EnergySolutions Wisconsin Department of Health Services 121 W. Trade Street, Suite 2700 P.O. Box 2659 Charlotte, NC 28202 Madison, WI 53701-2659 Joseph Nowak Brent Ridge General Manager President and CEO LaCrosseSolutions Dairyland Power Cooperative S4601 State Highway 35 3200 East Avenue South Genoa, WI 54632-8846 La Crosse, WI 54602-081 7 Gerard van N oordennen Cheryl Olson, ISFSI Manager Sr. VP 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, WI54632-8846 Russ Workman Lane Peters General Counsel La Crosse Boiling Water Reactor EnergySolutions Dairyland Power Cooperative 299 South Main Street, Suite 1700 S4601 State Highway 35 Salt Lake City, UT 84111 Genoa, WI 54632-8846 Jerome Pedretti, Clerk John Henkelman Town of Genoa La Crosse Boiling Water Reactor E860 Mundsack Road Dairyland Power Cooperative Genoa, WI 54632 S4601 State Highway 35 Genoa, WI 54632-8846 Jeffery Kitsembel Division of Energy Regulation Andrew J. Parrish Wisconsin Public Service Commission Wheeler, Van Sickle and Anderson, S.C.
P.O. Box 7854 44 East Mifflin Street, Suite 1000 Madison, WI 53707-7854
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LACROSSESOLUTIONS 2021 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR THE LACROSSE BOILING WATER REACTOR (LACBWR)
DATE: 03/03/2022 APPROVED BY: Scott i g~:.~U 5 00
~~~=b~o 6~~:~issioning, O":Energysolutions, CN=Scott Zoller, E"'s'g'zoller@energysolutlons.com
' Roason:lamapprovinglhisdocumonl Zoller Location:
. Date:.2022-03-08 12:40:59
. ; ~O~it PhantomPDF Version: 9.4. 1 Page 1 of 23
ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR THE LA CROSSE BOILING WATER REACTOR (LACBWR)
(January 1, 2021 to February 09, 2022)
LACROSSESOLUT/ONS S4601 STATE HIGHWAY 35 GENOA, WI 54632 Page 2 of 23
TABLE OF CONTENTS SECTION A: RADIOACTIVE EFFLUENT REPORT Section Title Introduction ........................... ~ .................................................... . 6 1.0 Regulatory Limits ........................................................................ . 8 2.0 Effluent Release Concentration Limit.. ...................................... .. 10 3.0 Average Energy .................... .' .................................................... . 10 4.0 Analytical Methods ..................................................................... .. 10 5.0 Releases .................................................................................... . 11 6.0 Abnormal Releases .............. .' ................................................... .. 11 7.0 Estimated Total Analytical Error ............................................... .. 11 8.0 Offsite Dose Calculation Summary and Conclusions ................. . 12 9.0 Offsite Dose Calculation Manual (ODCM) Review .................... .. 13 10.0 Process Control Program (PGP) Review .................................. .. 13 11.0 Errata Data ................................................................................ . 13 Page 3 of 23.
SECTION B: RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT I
Section Title Page Introduction.................................................................................. 15 1.0 Sample Collection ....................................................................... . 16 2.0 Results of the 2021 Radio-Environmental Monitoring Survey ... .. 16 3.0 Conclusions ...........................:.................................................... . 17 4.0 lnterlaboratory Comparison Program Results ............................ . 18 SECTION B: RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT Figure No. Title Page 1 LACBWR Property Map .............................................................. . 19 2 ISFSI Environmental TLD Locations ........................................ .. 20 SECTION B: RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT Table No. Title Page 1 ISFSI Environmental TLD Locations......................................... 21 2 Sample Frequency and Analysis of Radio Environmental Samples 22 3 Quarterly Environmental TLD Results for ISFSI Area 23 Page :4 of 23
Radioactive Effluent Report SECTION A RADIOACTIVE EFFLUENT REPORT Page 5 of 23
Radioactive Effluent Report INTRODUCTION The La Crosse Boiling Water Reactor (LACBWR), also known as Genoa Station No. 2, was located on the east bank of the Mississippi River near Genoa, Vernon County, i
Wisconsin. The plant was designed and constructed by the Allis-Chalmers Manufacturing Company. It was completed in 1967 and had a generation capacity of 50 MW (165 MW (th))- The reactor is owned by Dairyland Power Cooperative (DPC).
The reactor went critical in July 1967 and first contributed electricity to the DPC system in April 1968. After completing full power tests in August 1969, the plant operated between 60% and 100% full power, with the :exception of plant shutdowns for maintenance and repair until 1987.
In April of 1987 plant operation was ceased. The reactor was defueled and placed in a
- SAFSTOR mode. In August of 1987 a possession-only license was received. In 2007 the reactor vessel was removed from the site and buried at the Barnwell waste repository. In 2012 all spent fuel was placed in dry storage and placed at the LACBWR Independent Spent Fuel Storage lnstallation'(ISFSI).
In June of 2016 DPC, working with the selected decommissioning contractor LaCrosseSo/utions LLC, transferred their NRG License to LaCrosseSolutions LLC for the purposes of decommissioning the site to.unconditional release criteria, per the license termination plan. At the conclusion of CY 2018 all facilities inside the radiological restricted area were demolished and the contents placed into radioactive waste shipping containers. The focus in CY 2019 was to finish minor decommissioning work in the radiologically restricted area as needed, complete the final status surveys for the LACBWR site, and demobilize equipment arid personnel. As of October 2019, all LACBWR site field decommissioning work was completed including final status surveys (FSS) and Oak Ridge Associated Universities (ORAU) independent verification of final status surveys at NRG direction. Surveillances of excavation bases and after backfilling the excavations were performed in 2021 to confirm the results of the FSS were Page 6 of 23
Radioactive Effluent Report unchanged. The excavations were performed to install various utilities to support the decommissioning of the G-3 coal fired power plant and ancillary buildings.
In accordance with LC-RP-PG-004, "Radiological Environmental Monitoring Program and Preparation of the Annual Radiological Environmental Operating Report," this document provides the Annual Radiological Environmental Operating Report (AREOR) for the Period January 1, 2021 through February 09, 2022. All LACBWR site required effluent and environmental monitoring, other than for the LACBWR ISFSI, has been 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.
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Radioactive q:ffluent Report EFFLUENT AND WASTE DISPOSAL REPORT (Supplemental Information)
FACILITY: La Crosse Boiling Water Reactor LICENSEE: LaCrosseSolutions LICENSE NO. DPR-45 DOCKET NO. 50-409 & 72~046 1.0 REGULATORY LIMITS 1.1 Airborne Effluent Release Limits:
LACBWR airborne particulates, with ha'lf-lives greater than 8 days, released to areas beyond the Effluent Release Boundary shall be limited to </= 7 .5 mRem to any organ per calendar quarter and </= to 15 mRem to any organ per calendar year(10 CFR 50 Appendix I). The cumulative dose contributions from airborne particulate effluent releases are determined in accordance with the LaCrosseSolutions, LLC Offsite Dose Calculation Manual (ODCM) and consideration of 10 CFR 20 Appendix B Table 2 Column 1 concentration values. Additionally, gaseous effluents of beta radiation in the form of tritium, beyond the Effluent Release Boundary, shall be limited to 1O mRad per calendar quarter and 20 mRad per calendar year (10 CFR 50 Appendix I).
Also, in accordance with the provisions of 40 CFR 190, the restrictions for total dose to any member of the public from all LACBWR related sources and dose pathways are evaluated quarterly and on an annual basis during active decommissioning. No samples for airborne radioactivity were obtained in 2021 since active decommissioning ceased in 2019.
1.2 Liquid Effluent Release Limits:
LACBWR's liquid effluent release limitations are those concentrations specified in 10 CFR 20 Appendix B, Table 2, Column 2.. The values reported are either based on dilution of the effluent with the Genoa Station No. 3 condenser cooling water flow or no Page '8 of 23
Radioactive Effluent Report condenser cooling water flow prior to discharge to the Mississippi River. No credit is taken for further dilution in the mixing zo,ne of the Mississippi River.
Also, in accordance with 10 CFR 50, Appendix I, the dose commitment to a member of the public from radioactive materials released in liquid effluents to areas beyond the Effluent Release Boundary are limited to less than 1.5 mRem whole body and 5.0 mRem organ dose per calendar quarter; and less than 3.0 mRem whole body and 10 mRem organ dose per calendar year via the critical ingestion pathway. The cumulative dose contributions from liquid effluent releases are determined in accordance with the LaCrosseSolutions, LLC Offsite Dose Calculation Manual.
In accordance with the provisions of 40 CFR 190, the restrictions for total dose to any member of the public from all LACBWR related sources and dose pathways are evaluated quarterly and on an annual basis during active decommissioning. There were no liquid discharges from the LACBWR site in 2021, and no monitoring or sampling was performed.
1 .3 Solid Radioactive Waste All solid radioactive wastes are handled in accordance with a Process Control Program as defined by LaCrosseSolutions, LLC procedures, in order to assure that all applicable transportation and burial site disposal requirements are met. There were no shipments of radioactive waste in 2021 .-
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Radioactive Effluent Report 2.0 EFFLUENT RELEASE CONCENTRATION LIMIT The Liquid Effluent Release Concentration used to calculate permissible release rates are obtained from 10 CFR 20, Appendix B, Table 2, Column 2.
3.0 AVERAGE ENERGY The release rate limits for LACBWR are not based on average energy.
4.0 ANALYTICAL METHODS 4.1 Liquid Effluents Liquid effluent measurements for gross radioactivity are performed by HPGe gamma isotopic analysis of representative samples from each monitor tank or pump down release prior to discharge. In addition, each batch monitor tank or pump down sample is analyzed for tritium activity concentrations using site approved bench top analysis equipment. A composite sample is created by collecting representative aliquots from each tank batch or pump down release discharged during a calendar quarter. This composite is analyzed for: lron-55, Strontium-90, Nickel-59, Nickel-63, Americium-241, Plutonium-238, Plutonium 239/240, and Plutonium -241 by an off-site contractor on a quarterly basis.
4.2 Airborne Particulates Airborne particulate releases are determined by HPGe gamma isotopic analysis and gross beta and gross alpha analyses of glass fiber filter paper taken from four low volume air samplers placed either in prevailing downwind locations or in representative sampling locations on HEPA exhaust systems. The filter paper is changed out weekly and analyzed approximately one week later.
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Radioactive Effluent Report 5.0 RELEASES 5.1 Airborne To demonstrate compliance with the limits in Section 1.1 dose contributions have been calculated using a bounding assessment as described in Regulatory Guide 1.21. This analysis is summarized in the current Offsite Dose Calculation-Manual. Routine low volume air sampling is in place at four locations outside the RCA in the predominant typical downwind locations, to be used to demonstrate compliance with dose limits in Section 1.1 during remediation activities. Any HEPA system exhausting to the outside environment has representative air sampling performed of the exhaust air following passing thru the HEPA system also for the purposes of demonstrating compliance with Section 1.1 during remediation activities. No monitoring for airborne activity was performed in 2021 since all LACBWR site required effluent and environmental monitoring, other than for the LACBWR ISFSI, has been terminated as of October 2019.
5.2 Liquid All liquid effluent releases at LACBWR are batch releases or pump down releases as described in the ODCM. No liquid effluent was released in 2021.
6.0 ABNORMAL RELEASES There were no abnormal releases of radioactivity in plant effluents which exceeded release limits.
7.0 ESTIMATED TOTAL ANALYTICAL ERROR There is no estimated error in this report.
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Radioactive Effluent Report 8.0 OFFSITE DOSE CALCULATIONS
SUMMARY
AND CONCLUSIONS:
8.1 Particulate/Gaseous Effluent Releases The maximum quarterly offsite dose to any organ from the release of all radionuclides in particulate form with half-lives greater than 8 days was 0 mRem. The cumulative 2021 annual maximum organ dose from these radionuclides was also 0 mRem. The
- maximum quarterly offsite dose from gaseous beta emitters in the form of tritium is 0 mRad/quarter and overall for the year* released a total of 0 mRad.
8.2 Liquid Effluent Releases The maximum quarterly organ dose from liquid releases was 0 mRem. The cumulative 2021 annual organ dose was 0 mRem. The maximum quarterly total body dose for liquid releases was 0 mRem, and the cumulative 2021 annual total body dose was0 mRem.
8.3 Conclusion All calculated offsite doses were below all ODCM limits for airborne and liquids releases for CY 2021.
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Radioactive Effluent Report 9.0 OFFSITE DOSE CALCULATION MANUAL (ODCM) REVIEW No revisions were made to the ODCM in 2021.
10.0 PROCESS CONTROL PROGRAM (PCP) REVIEW The LaCrosseSolutions, LLC PCP was not revised in 2021.
11.0 ERRATA DATA None.
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Radioactive !:Effluent Report SECT:ION B ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT Page 14 of 23
ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT INTRODUCTION:
The Radiological Environmental Monitoring (REM) Program is conducted to comply with the requirements of the ODCM and in accordance with 10 CFR 50 Part 50.36a and 10 CFR
- 72. 104. The REM Program provides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuc/ides which could potentially lead to radiation doses to Members of the Public resulting from plant effluents. Environmental samples were taken within the surrounding areas of the plant and in selected background locations.
The monitoring program at the LACBWR fac(lity includes monitoring of liquid and airborne particulate releases from the plant, as well as collecting environmental samples of surface air, river water, river sediment, and ambient radiation.
The REM program therefore supplements the Radioactive Effluent analyses by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways using the methodology of the Offsite Dose Calculation Manual (ODCM).
An lnterlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental samples are performed.
All LACBWR site required environmental monitoring, other than for the LACBWR ISFSI, has been 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 I
work by ORAU of the radiologically restricted area.
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ANNUAL RADIOLOGICAL ENVIR1NMENTAL MONITORING REPORT 1.0 SAMPLE COLLECTION Environmental samples are collected from the area surrounding LACBWR at the frequencies outlined in the ODCM and the Environmental Monitoring Program. A series of figures and tables are included in this report to explain the LACBWR environmental program in 2021.
FIGURE 1 This map includes the plant exclusion boundary, roads, other generation plants, and the relationship of the plant to the nearest local community.
FIGURE 2 This map shows the location of ISFSI environmental TLDs.
TABLE 1 This table logs the environmental TLD locations at the ISFSI.
TABLE 2 Th is table shows the sampling frequency of the various environmental samples and the analyses performed on these samples TABLE 3 Quarterly Environmental TLD results for ISFSI Area 2.0 RESULTS OF THE 2021 ENVIRONMENTAL MONITORING SURVEYS During 2021, activity levels in the local environment were trending normal.
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ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT 2.1 PENETRATING RADIATION The environmental penetrating radiation dose is measured by environmental TLDs.
2.1.1 ISFSI - These environmental TLDs are exchanged on a quarterly basis.
Table 3 summarizes the results for 2021. Please note that due to supplier issues, the environmental TLDs were not exchanged in the fourth quarter until February 09, 2022. As such, the dose associated with the fourth quarter also includes the period from January 01, 2022 to February 09, 2022.
2.2 AIR PARTICULATE Air samples were collected continuously from various sites around LACBWR during decommissioning. Low volume particulate air samplers were used to collect air samples. The air filter consists of a glass fiber filter with an associated pore size of approximately 0.45 µm. The particulate filters were analyzed bi-weekly for gross beta activity with an internal proportional cou'nter, as well as analyzed by gamma spectroscopy for individual isotopic concentration. No air sampling was conducted in 2021.
2.3 RIVER WATER River water is collected semi-annually. River water samples before the intake structure, at plant outfall, and below the: plant outfall are collected and are gamma analyzed for isotopic concentration and tritium analysis. No samples of river water were collected in 2021.
2.4 SEDIMENT SAMPLES Sediment samples were collected semi-annually before the intake structure, at plant outfall, .and below the plant outfall. These samples were analyzed via gamma spectroscopy. No sediment samples were collected in 2021.
3.0 CONCLUSION
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ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT
. I All environmental samples collected and analyzed during 2021 exhibited no significant contribution from LACBWR or ISFSI operations. Also, in accordance with 40 CFR 190 requirements, all pathway doses to the environment for LACBWR Site for calendar year 2021 were evaluated and the summary for CY 2021 is:
Whole Body Dose: 0.18 mRem which is 0.72% of the annual limit 4.0 INTERLABORATORY COMPARISON PROGRAM RESULTS No interlaboratory comparison samples were analyzed in 2021, as the onsite laboratory was demobilized from the site in October of 2019.
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ANNUAL RADIOLOGICAL ENVIRQNMENTAL MONITORING REPORT FIGURE 1 - LACBWR PROPERTY MAP I
I I
I
~ I U.S. L;:11., /' T
- a OAld wru/
29"28 32 33 LOCATION- MAP EXCLUSION- BOl.JHDAl 110!1 ft rad1Cu 10::.., ........
~ 0 0 SCALE OF FEET T.~101-N., R.*3-W.
OF THE 5th P.M. -
JEFFERSON TOWNSHIP HOUSTON COUNTY, MINNESOTA SEC. 7 LIMITS SEc.. ,e 1t WELL LOT 3 T.-l!*N, , R.-7-W.
Ji WELfs OF THE 4th P.M.
,: oTOWN OF GENO~
l _ VERNON COUNTY\
'I[
LOT 7 LOT 4 WELL
- SEC. S 1:-12*N.1 I-.IOTt* ISLAND 126 IS UNDER TltE .
.IURISDICTl0N OF UPPE.li MISSISSIPPI RIVER WII.D INOICAll.S .. ILlS All0V£ tttt LIFE AND FISH REFUGE. 1-MOU'fti OF 1Ht: OHIO filYER. '
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ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT FIGURE 2 -ISFSI ENVIRONMENTAL TLD LOCATIONS l().flO.i.O -<A _ , ~
- rt'o,ll.
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ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT TABLE 1 ISFSI ENVIRONMENTAL TLD LOCATIONS LOCATION LOCATION NO.
1 ISFSI ADMINISTRATIVE BUILDING WEST 2 ISFSI PROTECTED AREA NORTH EAST SIDE 3 ISFSI PROTECTED AREA NORTH WEST SIDE 4 ISFSI PROTECTED AREA SOUTH WEST SIDE 5 ISFSI PROTECTED AREA SOUTH EAST SIDE 6 ISFSI OWNER CONTROLLED FENCE NORTH 7 ISFSI OWNER CONTROLLED FENCE WEST 8 ISFSI OWNER CONTROLLED FENCE EAST 9 ISFSI OWNER CONTROLLED FENCE NORTH EAST BY HEAVY HAUL PATH 10 ISFSI OWNER CONTROLLED FENCE WEST BY BOAT LANDING Page 21 of 23
I I
I ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT TABLE 2 SAMPLE FREQUENCY AND ANALYSIS OF RADIOLOGICAL ENVIRONMENTAL SAMPLES SAMPLE FREQUENCY* ANALYSIS PERFORMED Environmental TLDs Quarterly Dose in mRem Particulate Air - Glass Bi-Weekly Gross Beta and Gamma Fiber Filters Spectroscopy River Sediment Semi-annually Gamma Spectroscopy River Water Semi-annually Gamma Spectroscopy and Tritium (Liquid Scintillation Analyzer)
NOTE:
All LACBWR site required effluent and environmental monitoring, other than for the LACBWR ISFSI, has been 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 wo~k by ORAU of the radiologically restricted area.
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ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT TABLE 3 QUARTERLY ENVIRONMENTAL TLD RESULTS FOR ISFSI AREA JANUARY 2021-FEBRUARY 09,2022 STATION NO.
- 1st QUARTER 2nd QUARTER 3rd QUARTER 4TH Quarter mRem mRem mRem mRem 1 </=BKG 3.0 2.0 5.0.
2 24.0 20.0 20.0 37.0 3 73.0 77.0 70.0 67.0 4 16.0 15.0 13.0 6.0 5 21.0 25.0 26.0 37.0 6 (*) </=BKG 0.01 0.01 0.04 7(*) 0.01 0.02 0.01 0.06 8 (*) 0.02 0.03 0.02 0.05 9 (*) </=BKG 0.02 0.02 </=BKG 10 (*) 0.02 0.05 0.04 0.07 ALL BACKGROUND CORRECTED AND THOSE ON OWNER CONTROLLED AREA FENCE LINE IDENTIFIED WITH(*) HAD OCCUPANCY FACTOR CORRECTION APPLIED IF> BACKGROUND TLD RESULTS Page 23 of 23