ML16245A377

Post-Shutdown Decommissioning Activities Report Review Letter

ML16245A377
Person / Time
Site:	La Crosse  File:Dairyland Power Cooperative icon.png
Issue date:	09/06/2016
From:	Vaaler M Reactor Decommissioning Branch
To:	Nick B, Sauger J Dairyland Power Cooperative, EnergySolutions
VAALER M, 415-3178, T-8F05
References
CAC L53135
Download: ML16245A377 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 6, 2016 Ms. Barbara A. Nick President and Chief Executive Officer Dairyland Power Cooperative 3200 East Avenue South P.O. Box 817 La Crosse, WI 54602-0817

SUBJECT:

LA CROSSE BOILING WATER REACTOR - REVIEW OF AMENDED POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT (CAC NO. L53135)

Dear Ms. Nick:

By letter dated June 27, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16181A117), LaCrosseSolutions, LLC (LS or the licensee) submitted an update to the Decommissioning Plan and Post-Shutdown Decommissioning Activities Report (D-Plan/PSDAR) for the La Crosse Boiling Water Reactor (LACBWR) pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.82(a)(7). The purpose of this letter is to provide you with the results of the U.S. Nuclear Regulatory Commission (NRC) staffs review of the amended LACBWR D-Plan/PSDAR.

The LACBWR D-Plan/PSDAR contains a description of the planned decommissioning activities, the overall decommissioning schedule, an estimate of expected decommissioning costs (i.e.,

the Decommissioning Cost Estimate (DCE)), and an assessment of the potential environmental impacts of decommissioning. The LACBWR D-Plan/PSDAR is also recognized as the site Safety Analysis Report (SAR) equivalent as it contains the plant post-fuel accident analysis, and is being updated in accordance with the periodicity requirements in 10 CFR 50.71(e)(4).

The D-Plan/PSDAR update submitted on June 27, 2016, reflects transfer of the LACBWR operating license from the Dairyland Power Cooperative (DPC) to LS, which went into effect on June 1, 2016, and assigns DPCs licensed possession, maintenance, and decommissioning authorities for LACBWR to LS in order to implement expedited decommissioning of the LACBWR site. The NRC approved the direct transfer of Possession Only License No. DPR-45 from DPC to LS by order dated May 20, 2016 (ADAMS Accession No. ML16123A073).

The purposes of the D-Plan/PSDAR and DCE are to: (1) inform the public of the licensees planned decommissioning activities, (2) assist in the scheduling of NRC resources necessary for the appropriate oversight activities, (3) ensure that the licensee has considered all of the costs of the planned decommissioning activities and the funding for the decommissioning process, and (4) ensure that the environmental impacts of the planned decommissioning activities are bounded by those considered in existing environmental impact statements.

Pursuant to 10 CFR 50.82(a)(4)(i), the PSDAR must contain a description of the planned decommissioning activities along with a schedule for their accomplishment, a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements, and a site-specific DCE, including the projected cost of managing spent fuel.

The NRC staff reviewed the LACBWR D-Plan/PSDAR and DCE against the requirements in 10 CFR 50.82(a). In addition, the staff used the guidance in Regulatory Guide (RG) 1.185, Revision 1 (RG 1.185), Standard Format and Content for Post-Shutdown Decommissioning Activities Report, dated June 2013 (ADAMS Accession No. ML13140A038), in conducting its review and concludes the following:

1. Section 1 of the D-Plan/PSDAR, Description of Planned Decommissioning Activities, provides the applicable information identified in Section C.1 of RG 1.185. The NRC staff's review found that the licensee appropriately described the activities associated with the major milestones related to the remaining decommissioning of the LACBWR site, as required by 10 CFR 50.82(a)(4)(i), and consistent with RG 1.185.

2. Section 2 of the D-Plan/PSDAR, Schedule, provides the estimated dates for completion of major decommissioning activities, as required by 10 CFR 50.82(a)(4)(i), and consistent with Section C.2 of RG 1.185. The NRC staff finds that the schedule for decommissioning activities is adequate to achieve LACBWR license termination within 60 years of permanent cessation of operations, as required by 10 CFR 50.82(a)(3).

3. Section 3 of the D-Plan/PSDAR, Estimate of Expected Decommissioning Costs, provides an estimate of the expected decommissioning costs for the remaining activities at LACBWR.

The NRC staff reviewed the cost estimate against the guidance in Section C.3 of RG 1.185 and finds that LSs site-specific estimate for LACBWR is considered reasonable, is described consistent with the guidance in RG 1.185, provides sufficient details associated with the funding mechanisms, and meets the requirements of 10 CFR 50.82(a)(4)(i).

4. Section 5 of the D-Plan/PSDAR, Environmental Impact, provides a discussion of the potential environmental impacts associated with the LACBWR decommissioning activities, as identified by Section C.4 of RG 1.185. The D-Plan/PSDAR concludes that the environmental impact of decommissioning and dismantlement activities at LACBWR is SMALL, as defined in NUREG-0586, Initial Report, Final Generic Environmental Impact Statement [GEIS] on Decommissioning of Nuclear Facilities, dated August 1988, and Supplement 1, dated November 2002. The GEIS and supplement evaluated the environmental impacts of decommissioning activities at nuclear power reactors necessary to reduce the residual radioactivity to levels that allow for the termination of the NRC license.

The LACBWR decommissioning process was specifically evaluated in the GEIS, and the licensee concluded that the environmental impacts of the remaining decommissioning activities continue to be bounded by the analysis provided in NUREG-0586. After reviewing the licensee's information, the NRC staff finds that the potential environmental impacts associated with LACBWR decommissioning activities are bounded by the previously issued GEIS and its supplements, are described consistent with the guidance in RG 1.185, and meet the requirements of 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(6)(ii).

Based on this review, the NRC staff finds that the LACBWR D-Plan/PSDAR contains the information required by 10 CFR 50.82(a)(4)(i), and is consistent with RG 1.185. In accordance with 10 CFR 50.82(a)(7), LS must notify the NRC in writing before performing any significant decommissioning activity inconsistent with, or making a significant schedule change from, the planned decommissioning activities or schedules described in the LACBWR D-Plan/PSDAR, including changes that significantly increase the decommissioning costs.

In accordance with 10 CFR Part 2, "Agency Rules of Practice and Procedure," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions regarding this letter, please contact me at 301-415-3178, or by e-mail at Marlayna.Vaaler@nrc.gov.

Sincerely,

/RA/

Marlayna Vaaler, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-409 and 72-046 License No.: DPR-45 cc: La Crosse Boiling Water Reactor Service List

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. John Sauger Executive Vice President Chief Nuclear Officer Reactor D & D EnergySolutions 2701 Deborah Avenue Zion, IL 60099

SUBJECT:

LA CROSSE BOILING WATER REACTOR - REVIEW OF AMENDED POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT (CAC NO. L53135)

Dear Mr. Sauger:

By letter dated June 27, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16181A117), LaCrosseSolutions, LLC (LS or the licensee) submitted an update to the Decommissioning Plan and Post-Shutdown Decommissioning Activities Report (D-Plan/PSDAR) for the La Crosse Boiling Water Reactor (LACBWR) pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.82(a)(7). The purpose of this letter is to provide you with the results of the U.S. Nuclear Regulatory Commission (NRC) staffs review of the amended LACBWR D-Plan/PSDAR.

The LACBWR D-Plan/PSDAR contains a description of the planned decommissioning activities, the overall decommissioning schedule, an estimate of expected decommissioning costs (i.e.,

the Decommissioning Cost Estimate (DCE)), and an assessment of the potential environmental impacts of decommissioning. The LACBWR D-Plan/PSDAR is also recognized as the site Safety Analysis Report (SAR) equivalent as it contains the plant post-fuel accident analysis, and is being updated in accordance with the periodicity requirements in 10 CFR 50.71(e)(4).

The D-Plan/PSDAR update submitted on June 27, 2016, reflects transfer of the LACBWR operating license from the Dairyland Power Cooperative (DPC) to LS, which went into effect on June 1, 2016, and assigns DPCs licensed possession, maintenance, and decommissioning authorities for LACBWR to LS in order to implement expedited decommissioning of the LACBWR site. The NRC approved the direct transfer of Possession Only License No. DPR-45 from DPC to LS by order dated May 20, 2016 (ADAMS Accession No. ML16123A073).

The purposes of the D-Plan/PSDAR and DCE are to: (1) inform the public of the licensees planned decommissioning activities, (2) assist in the scheduling of NRC resources necessary for the appropriate oversight activities, (3) ensure that the licensee has considered all of the costs of the planned decommissioning activities and the funding for the decommissioning process, and (4) ensure that the environmental impacts of the planned decommissioning activities are bounded by those considered in existing environmental impact statements.

Pursuant to 10 CFR 50.82(a)(4)(i), the PSDAR must contain a description of the planned decommissioning activities along with a schedule for their accomplishment, a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements, and a site-specific DCE, including the projected cost of managing spent fuel.

The NRC staff reviewed the LACBWR D-Plan/PSDAR and DCE against the requirements in 10 CFR 50.82(a). In addition, the staff used the guidance in Regulatory Guide (RG) 1.185, Revision 1 (RG 1.185), Standard Format and Content for Post-Shutdown Decommissioning Activities Report, dated June 2013 (ADAMS Accession No. ML13140A038), in conducting its review and concludes the following:

5. Section 1 of the D-Plan/PSDAR, Description of Planned Decommissioning Activities, provides the applicable information identified in Section C.1 of RG 1.185. The NRC staff's review found that the licensee appropriately described the activities associated with the major milestones related to the remaining decommissioning of the LACBWR site, as required by 10 CFR 50.82(a)(4)(i), and consistent with RG 1.185.

6. Section 2 of the D-Plan/PSDAR, Schedule, provides the estimated dates for completion of major decommissioning activities, as required by 10 CFR 50.82(a)(4)(i), and consistent with Section C.2 of RG 1.185. The NRC staff finds that the schedule for decommissioning activities is adequate to achieve LACBWR license termination within 60 years of permanent cessation of operations, as required by 10 CFR 50.82(a)(3).

7. Section 3 of the D-Plan/PSDAR, Estimate of Expected Decommissioning Costs, provides an estimate of the expected decommissioning costs for the remaining activities at LACBWR.

The NRC staff reviewed the cost estimate against the guidance in Section C.3 of RG 1.185 and finds that LSs site-specific estimate for LACBWR is considered reasonable, is described consistent with the guidance in RG 1.185, provides sufficient details associated with the funding mechanisms, and meets the requirements of 10 CFR 50.82(a)(4)(i).

8. Section 5 of the D-Plan/PSDAR, Environmental Impact, provides a discussion of the potential environmental impacts associated with the LACBWR decommissioning activities, as identified by Section C.4 of RG 1.185. The D-Plan/PSDAR concludes that the environmental impact of decommissioning and dismantlement activities at LACBWR is SMALL, as defined in NUREG-0586, Initial Report, Final Generic Environmental Impact Statement [GEIS] on Decommissioning of Nuclear Facilities, dated August 1988, and Supplement 1, dated November 2002. The GEIS and supplement evaluated the environmental impacts of decommissioning activities at nuclear power reactors necessary to reduce the residual radioactivity to levels that allow for the termination of the NRC license.

The LACBWR decommissioning process was specifically evaluated in the GEIS, and the licensee concluded that the environmental impacts of the remaining decommissioning activities continue to be bounded by the analysis provided in NUREG-0586. After reviewing the licensee's information, the NRC staff finds that the potential environmental impacts associated with LACBWR decommissioning activities are bounded by the previously issued GEIS and its supplements, are described consistent with the guidance in RG 1.185, and meet the requirements of 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(6)(ii).

Based on this review, the NRC staff finds that the LACBWR D-Plan/PSDAR contains the information required by 10 CFR 50.82(a)(4)(i), and is consistent with RG 1.185. In accordance with 10 CFR 50.82(a)(7), LS must notify the NRC in writing before performing any significant decommissioning activity inconsistent with, or making a significant schedule change from, the planned decommissioning activities or schedules described in the LACBWR D-Plan/PSDAR, including changes that significantly increase the decommissioning costs.

In accordance with 10 CFR Part 2, "Agency Rules of Practice and Procedure," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions regarding this letter, please contact me at 301-415-3178, or by e-mail at Marlayna.Vaaler@nrc.gov.

Sincerely,

/RA/

Marlayna Vaaler, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-409 and 72-046 License No.: DPR-45 cc: La Crosse Boiling Water Reactor Service List

ML16245A377 OFFICE NMSS/RDB/PM NMSS/DUWP/LA NMSS/RDB/BC NAME MVaaler CHolston (MGV for)

BWatson DATE 9/1/2016 9/1/2016 9/6/2016

La Crosse Boiling Water Reactor Service List:

Ken Robuck Group President Disposal and Decommissioning EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger Executive VP and Chief Nuclear Officer Reactor DD EnergySolutions 2701 Deborah Avenue Zion, IL 60099 Gerard van Noordennen VP Regulatory Affairs EnergySolutions 2701 Deborah Avenue Zion, IL 60099 Joseph Nowak General Manager LaCrosseSolutions S4601 State Highway 35 Genoa, WI 54632-8846 Dan Shrum Senior VP Regulatory Affairs EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 Russ Workman General Counsel EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 George Kruck, Chairman Town of Genoa S5277 Mound Ridge Road Genoa, WI 54632 Regional Administrator U.S. NRC, Region III 2443 Warrenville Road Lisle, IL 60532-4352 Jeffery Kitsembel Electric Division Wisconsin Public Service Commission P.O. Box 7854 Madison, WI 53707-7854 Paul Schmidt, Manager Radiation Protection Section Bureau of Environmental and Occupational Health Division of Public Health Wisconsin Department of Health Services P.O. Box 2659 Madison, WI 53701-2659 Barbara Nick President and CEO Dairyland Power Cooperative 3200 East Avenue South, La Crosse, WI 54602-0817 Cheryl Olson, ISFSI Manager La Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 P.O. Box 817 Genoa, WI 54632-8846 Lane Peters, Site Manager La Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 Genoa, WI 54632-8846 Thomas Zaremba Wheeler, Van Sickle and Anderson, S.C.

44 East Mifflin Street, Suite 1000 Madison, WI 53703 John E. Matthews Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20