3F0124-01, Response to Request for Additional Information for the Additional Information Assessment of the License Termination Plan for Crystal River, Unit 3 Nuclear Generating Plant (Public Version)
| ML24086A459 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/18/2024 |
| From: | Reid B ADP CR3 |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| 3F0124-01 | |
| Download: ML24086A459 (1) | |
Text
ADP CR3, LLC CR3 Decommissioning 15760 West Power Line Street I Crystal River, FL 34428 3F0124-01 January 18, 2024 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Docket Nos. 50-302 & 72-1035, Operating License Number DPR-72 Crystal River Unit 3 Nuclear Power Station Billy Reid, Site Executive Cellphone: 865-384-6789 Email: breid@northstar.com 10 CFR 50.90 10 CFR 50.82 (a)(9)
Subject:
Response to REQUEST FOR ADDITIONAL INFORMATION FOR THE ENVIRONMENT AL ASSESSMENT OF THE LICENSE TERMINATION PLAN FOR CRYSTAL RIVER UNIT 3 NUCLEAR GENERA TING PLANT (DOCKET NUMBER:
05000302)
References:
- 1. NRC Letter to ADP CR3, "Request For Additional Information for the Environmental Assessment of the License Termination Plan for Crystal River Unit 3 Nuclear Generating Plant (Docket Number: 05000302), dated November 15, 2023 (ML23313A132).
Dear Commissioners and Staff,
By letter dated November 15, 2023 (Reference 1) (ML23313A132), the NRC provided ADP CR3 with a Request for Additional Information (RAI) for the Environmental Assessment of the License Termination Plan (L TP) for Crystal River Unit 3 Nuclear Generating Plant. In support of the U.S. NRC staffs technical review of the LTP, Attachment 1 of this letter provides the responses to the RAis.
There are no new regulatory commitments contained within this letter.
If you have any questions regarding this submittal or require additional information, please contact Mr. Billy Reid at 865-384-6789.
I state under penalty of perjury that the foregoing is true and correct. Executed on January 18, 2023.
Page 1 of 2
Sincerely, Cc: Regional Administrator, Region I NMSS Project Manager Environmental Review Materials Branch Chief Attachments:
- 1. Response to Request For Additional Information
Enclosures:
- 1. Terrestrial Ecology Correspondence
- 2. Environmental Justice Evaluation
- 3. Waste Acceptance Grouping Identification Plan
- 4. SHPO Correspondence
- 5. Cultural Resource Assessment 191 Page 2 of 2
191 Response to Request For Additional Information Permitting (PR) RAI PR-1: Provide a list of the various Federal, State, and local agency licenses and permits issued to ADP related to the decommissioning activities associated with the License Termination Plan (LTP).
Response: The permits issued to ADP related to the decommissioning activities are as follows:
Florida Department of Environmental Protection {FDEP) issued Multi-Sector General Permit No.
FLR05I568-001 FDEP issued Industrial Wastewater Discharge Permit No. FLOA00004 FDEP issued Environmental Resource Permit No. 09-0270612-042-EI Florida Department of Business and Professional Regulation issued General Contractor license No. CGC1527969 As discussed during the onsite meeting on 6 December 2023, the intake structure will remain in use by Units 4 and 5. It has not yet been determined if the discharge structure will be decommissioned, but if any bank or canal work is planned, the work will be completed under both the state and US Army Corps of Engineers permits, as applicable. Required permits will be obtained prior to any bank or canal work.
Land Use (LU) RAI LU-1: Are there plans to revegetate or recontour the land surface for areas disturbed by decommissioning areas?
Response: All disturbed areas will be stabilized with gravel, contouring, or vegetation to limit erosion and minimize runoff of soils to the surface waters (discharge and intake canals).
Transportation (TR) RAI TR-1: LTP section 8.5.2.15 states, "The transportation impacts of decommissioning are dependent on the number of shipments to and from the plant, the types of shipments, the distance the material is shipped, and the radiological waste quantities and disposal plans." The section further states that most waste will be shipped by rail for both radiological and non-radiological waste. Provide an estimate of the number of rail shipments, and truck shipments, if applicable.
Response: The following table provides the estimated number of shipments completed through January 2024, and the estimated number of shipments anticipated from January 2024 through project completion.
Page 1 of 7 3F0124-01 / Attachment 1 / Page 1 of 7
A1 Shipment Transportation Oct 2020 - Dec. 2023 Jan 2024 - Completion Trucks Rad Waste 42 10 Non-Rad Waste 133 0
Rail Rad Waste 160 250 Non-Rad Waste 0
0 Barge Rad Waste 0
4 Non Rad Waste 0
0 Water Resource (WR) RAI WR-1: LTP section 8.5.2.3 states that, "... during the planning and dormancy periods, stormwater runoff and drainage paths will be maintained in their current configuration." Will drainage paths be altered during active decommissioning activities? If so, discuss how they will potentially be altered and if there could be onsite or offsite impacts to land use or cultural sites.
Response: Drainage patterns will remain in their current conditions to the extent possible. On the berm, structures will be removed, and any asphalt that is removed will be backfilled with gravel and/or topsoil, with the existing stormwater system expected to remain in place. Off the berm, the current drainage patterns should remain with no current plans of alteration. Storm sewers will remain in place in paved areas and the drainage swales should not be altered in the grassy or unpaved areas.
Terrestrial Ecology (TE) RAI TES-1: Provide copies of any correspondence with the U.S. Fish and Wildlife Service or National Oceanic and Atmospheric Administration Fisheries since shutdown of the plant.
Response: Clarification was provided during the onsite meeting on 6 December 2023 that the timeframe for requested correspondence with the U.S. Fish and Wildlife Service (FWS) or National Oceanic and Atmospheric Administration Fisheries (NMFS) is from the time CR3 was transferred to ADP (since October 2020). The only correspondence was in association with the federal requirements for sea turtle incidental take coverage at the intake structure, where Duke Energy discussed removing the coverage for CR3 and transferring coverage under the Citrus facility to which NMFS agreed. Correspondence between NMFS and both FDEP and the NRC is provided as an enclosure to this letter in Attachment 1.
Aquatic Ecology (AE) RAls AE-1: What are the applicant's plans for receiving permits from US Army Corps of Engineers and the State of Florida for ground disturbance to remove shoreline structures?
Response: If the discharge structure is to be removed or altered, then US Army Corps of Engineers and FDEP permits would be warranted. Any work along the bank or below the highwater line will be conducted in accordance with the applicable permits.
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At1 AE-2: Provide overview (general) information on water intake and discharges from Duke Units 4 and 5.
Response: In addition to discharges of stormwater during severe events (such as tropical storms or hurricanes), Duke Energy Crystal River Units 4 and 5 only discharge cooling water to surface waters. The station has two sources of makeup water for the two cooling towers. The main source is the blowdown discharge and augmentation water from the Citrus Combined Cycle (CCC) station (the CCC blowdown gets reused as cooling water instead of being discharged to surface waters). The second source of makeup water for Units 4 and 5 is the intake structure with a maximum design flow of 49 million gallons per day {MGD). The Units 4 and 5 intake channel has two weirs that connect the intake channel to the blowdown channel to handle excess makeup water. The discharge flow for Units 4 and 5 is measured at each cooling tower and will depend on the operation of the units, with monthly average discharge values ranging from 33.9 to 96.6 MGD in 2023.
AE431: Provide copy of any permits from US Army Corps of Engineers for dredging for Duke Units 4 and
- 5.
Response: Other than some initial planning work for potential maintenance dredging over a decade ago (that was cancelled), no other maintenance dredging has been performed for Units 4 and 5.
Socioeconomics (SOC) RAls SOC-1: LTP section 8.5.2.10 states that there has been a decrease in the number of jobs due to decommissioning. Please provide an estimate of the number of workers that are currently employed or will be employed during the various phases of decommissioning, and for comparison purposes the number of workers during operations.
Response: There were approximately 50 staff employed when CR3 was in SAFSTOR, after the plant shut down in September 2009. There are between approximately 80 and 200 workers onsite as part of the decommissioning, and it is anticipated that approximately 30 staff will be needed for ongoing security and oversight following the completion of decommissioning. During operations, prior to 2009 there were approximately 600 workers on site, all living locally.
SOC-2: Please provide a description of where the workers reside during employment (i.e., are the workers commuting from nearby towns or local to the area where the plant resides).
Response: The security and management staff for both the decommissioning and the anticipated management of the independent spent fuel storage installation {ISFSI} following the completion of decommissioning are local to the area. During decommissioning, many of the workforce (approximately 80% or more) are local to the area, with the rest of the workforce being specialty trained Subject Matter Experts residing outside of Florida.
1 The original letter uses AE-2 twice, and we believe this was an error. We have renumbered this RAI to AE-3 for clarity in future discussions.
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191 Waste Management (WM) RAls WM-1: Provide the name of the municipal solid waste or construction and demolition waste landfill that will be used. Also, provide an estimated volume of the solid non-hazardous waste that will be disposed of at a municipal solid waste or construction and demolition waste landfill.
Response: All radiological waste will be disposed of at Waste Control Specialists in Andrews, Texas.
Non-radiological solid (soil) waste has gone to Republic Services' Cedar Trail Landfill in Bartow, Florida.
To date, approximately 3,700 tons of soil has been disposed of at this location from the non-radiological remediation of the Former Shooting Range and the Settling Pond. Clean concrete that has been painted or coated will either be disposed of at Sandland of Florida Enterprises, Inc. in Hernando, Florida or used as beneficial reuse material by Sean M. Gerrits, Inc. in Crystal River, Florida. Other demolition debris (i.e.,
cabling materials) has been recycled using the Scrap King facility in Tampa, Florida.
WM-2: Provide staff with a copy of the waste management plan mentioned in LTP section 8.5.1.3.
Response: The Waste Acceptance Grouping {WAG) Identification Plan describes how each waste group will be characterized. A copy of the report is provided in Attachment 3.
WM-3: Provide the estimated volumes of low-level radioactive waste by Class type and the intended disposal facility or provide direction to where this information can be found.
Response: The estimated volumes of /ow-level radioactive waste by class and intended disposal facility is provided in the table below:
Waste Class Estimated Volume Disposal Facility Class A 800,000 cubic ft wcs Class B 1,500 cubic ft wcs Class C 866 cubic ft wcs Greater than Class C 600cubicft ISFSI (on Site)
Historic and Cultural (HC) RAls HC-1: LTP section 8.5.2.12 states that "... [the] license renewal evaluation is also applicable to the decommissioning period... " It is unclear on how the predicted effects from license renewal (i.e.,
maintain status quo of activities) and the predicted effects from decommissioning activities (e.g.,
deconstruction, removal of sub/surface infrastructure, soil removal) are similar given the proposed activities. With respect to the presence/absence of cultural resources in the area of potential effect
{APE), please provide the rationale for why the evaluation of cultural resources would be applicable given the different type of activities for the various phases.
Response: All areas where decommissioning activities are taking place have been previously disturbed during construction and should not encroach on or impact native soils or habitats. Per the SHPO consultation, the State of Florida did not have any concerns with the existing structures within the APE, or any issues with respect to potential cultural resources.
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191 HC-2: Please provide any documentation of coordination with the Florida State Historic Preservation Office (SHPO) and/or Tribes regarding planned LTP decommissioning activities.
Response: The request letter to SHPO as well as their response is provided as an enclosure to this letter, in Attachment 4.
HC-3: Please provide a copy of the Miller (1973) reference cited in the historic and cultural analysis and any other supporting cultural resources survey reports used to evaluate the site.
Response: The Miller reference has not been located. However, there has been a more recent study conducted for Duke Energy by Search, Inc. in 2014 which is provided as Attachment 5. The L TP will be revised to reflect this reference in place of the Miller reference.
HC-4: Facility construction was authorized in 1968 and completed in 1976 - therefore, the completed facility will be 50 years of age in 2026. Given the age of the facility and to assist staff in assessing the potential presence of historic properties, per 36 CFR 800.4 "Identification of Historic Properties,"
provide an evaluation of the historic nature of the facility to determine its National Register of Historic Places-eligibility. Please submit the evaluation report and any associated correspondence with Florida SHPO.
Response: Please see response to HC-2 for the ruling from SHPO. Based on SHPO's response, an evaluation per 36 CFR 800.4 was not conducted as the project is projected to be completed by 2026.
HC-5: Please provide a map of the APE with respect to decommissioning activities for CR3, including any lay down areas or land used for temporary storage of materials associated with decommissioning so that staff can evaluate potential impacts to cultural resources. In addition, please provide thorough documentation of previously recorded cultural resources in the Crystal River Energy Complex (CREC) operating area and adjacent parcels so that direct and indirect effects upon cultural resources may be adequately evaluated and addressed.
Response: Please see response to HC-3 regarding the cultural resources study completed in 2014. In addition to that study, Southeastern Archaeological Research, Inc. completed two studies in 2011 and Archaeological Consultants, Inc. completed a study in 1996 in Citrus County areas. These studies are provided in Attachment 5. A map of the APE is provided below.
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A1
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Anticipated APE areas for the decommissioning of ADP CR3. Red areas highlight APE for ADP-CR3, blue areas highlight APE for Units 1 and 2, already completed.
HC-6: Please provide a copy of corporate procedure "EVC SUBS 00105 -Archaeological and Cultural Resources."
Response: This procedure has been closed by Duke and replaced by procedure PRG-ENV-01-015. The LTP will be revised to reflect the correct procedure. Due to proprietary information, a copy of the procedure will be uploaded to the portal for viewing purposes rather than provided as an enclosure to this letter.
HC-7: Was a cultural resources management plan prepared pursuant to the draft supplemental environmental impact statement (SEIS) (NUREG-1437, Supplement 44)? Please provide a discussion of why or why not. If a cultural resources management plan was prepared, please provide a copy.
Response: Based on the SHPO response included in HC-2, a cultural resources management plan was not warranted.
HC-8: Has CREC been subject to modern cultural resources survey? If not, please provide a discussion as to why a modern cultural resources survey is not warranted.
Response: Please see response to HC-3 regarding the cultural resources study completed in 2014.
Air Quality {AQ) RAls AQ-1: The LTP states that the site contains two coal fossil-fueled units. The draft SEIS (NUREG-1437, Supplement 44) states that CREC had four coal-fired units (CR-1, CR-2, CR-4, and CR-5) and that units CR-1 and CR-2 were planned for shutdown in 2020. Verify that these two units are shutdown. Are the Page 6 of 7 3F0124-01 / Attachment 1 / Page 6 of 7
191 remaining two units {CR-4 and CR-5) currently operating and is operation planned to continue after decommissioning of CREC?
Response: Units 1 and 2 were shutdown in 2020 and have since been decommissioned and demolished.
The remaining two units {CR-4 and CR-5) are currently operating and are scheduled to remain operating after the decommissioning of CR-3.
AQ-2: What is the status of the Title V Permit for CREC? The LTP states that the emergency diesel generators were recently exempted from the Title V and that a Notice of Intent was filed. Does the permit cover other sources of emissions from CR-3?
Response: During the property transfer from Duke Energy to ADP, a Notice of Intent was filed with the State of Florida, as the amount of anticipated emissions and point sources are exempt from Title V. CREC does have a Title V permit for the remaining active plants, and that permit is held by Duke Energy.
AQ-3: Describe how often coal deliveries to the CREC site occur and the delivery method (e.g., barge, truck, rail).
Response: Coal deliveries occur typically 2-3 times a week per barge. All deliveries will be completed via barge until summer 2024 when rail repairs are scheduled to be completed.
AQ-4: The LTP states that "[o]utside the licensed footprint are 2 gas combined cycle units." What distance are these 2 units located from CREC? When did these units begin operating?
Response: The gas combined cycle units are located approximately 2 miles from CR-3. They began operating in October and November 2018.
AQ-5: Provide the workforce at the time CR-3 ceased operation, an estimate of the number of workers onsite during decommissioning and where the workers would likely be commuting from (e.g.,
surrounding counties). Will the workforce decrease as decommissioning progresses? A response to this RAI could be incorporated into the SOC-1 response.
Response: Please see response to SOC-1.
Cumulative Impacts (Cl) RAI Cl-1: Provide a discussion on present and reasonably foreseeable future actions in the area that could have impacts overlapping in time or place with the impacts from this proposed action. For example, are there currently operating or planned construction of commercial or industrial facilities that could have overlapping effects on traffic, groundwater resources, or other resources?
Response: Other than the recent demolition of the Crystal River Mall {located approximately 6.5 miles
[by roadway] from CR-3 on US Route 19, south of CREC), which was started in March 2023 and will be completed in early 2024, there are no other known significant projects planned or currently underway that could impact traffic or environmental resources.
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Terrestrial Ecology Correspondence BEGINS ON NEXT PAGE 3F0124-01 / Enclosure 1 / Docket No. 50-302
January 24, 2022 Jack D. Parrott Senior Project Manager U.S. Nuclear Regulatory Commission Mailstop T-5A10 Washington, DC 20555
Subject:
Status of Section 7 Consultation Under The Endangered Species Act for the cooling water intake system at the Crystal River Energy Complex (F/SER/2001/01080).
Dear Mr. Parrott:
The National Marine Fisheries Service (NMFS) issued a Biological Opinion to the U.S. Nuclear Regulatory Commision (NRC) for the cooling water intake system at the Crystal River Energy Complex on August 8, 2002 (hereafter refered to as the CREC biological opinion). The cooling water intake has been repurposed and modified for the Duke Energy Citrus Combined Cycle Station and is currently compliant with the Programmatic Biological Opinion on the U.S.
Environmental Protection Agencys Issuance and Implementation of the Final Regulations Section 316(b) of the Clean Water Act on May 19, 2014 (hereafter refered to as the 316(b) biological opinion). As part of the 316(b) biological opinion process, NMFS received the most recent request for technical assistance from the Florida Department of Environmental Protection on the Duke Energy Citrus Combined Cycle Station National Pollutant Discharge Elimination System Permit Application Renewal (FL0000159) on June 7, 2021. NMFS responded to this request in a letter dated June 9, 2021 with no suggested control measures or conservation recommendations beyond those presented in the 316(b) biological opinion.
The Permit Application Renewal (FL0000159) indicates the Crystal River Energy Complex cooling water intake is now part of the Duke Energy Citrus Combined Cycle Station and no longer in use for nuclear power generation. Based on this information, the 2002 CREC biological opinion is no longer applicable. No further action is required of the NRC concerning the CREC biological opinion.
If you have any questions, please contact Joe Heublein on my staff at (727) 209-5962 or joe.heublein@noaa.gov.
Sincerely, Nicholas A. Farmer, Ph.D.
Chief, Species Conservation Branch CC:
Briana Arlene, NRC 3F0124-01 / Enclosure 1 / Page 1 of 3
July 9, 2021 Frank Wall Engineering Specialist IV Florida Department of Environmental Protection Division of Water Resource Management Wastewater Management Program Power Plant Permitting 2600 Blair Stone Road MS 3545 Tallahassee, FL 32399
Subject:
NPDES Permit Application Technical Assistance, FL0000159 Duke Energy Citrus Combined Cycle Station Permit Renewal
Dear Mr. Wall:
Thank you for the opportunity to review the National Pollutant Discharge Elimination System permit application submitted by Duke Energy Citrus Combined Cycle Station to Florida Department of Environmental Protection pursuant to Section 316(b) of the Clean Water Act (CWA), as amended, and the Code of Federal Regulations, Title 40, Parts 122 and 125. Our 60-day review began when we received the permit application on June 7, 2021. Our comments below are based on the permit application. Pursuant to existing regulations at 40 CFR 124.10(c)(1)(iv) and (e), we also have the opportunity to review the draft permit. If the draft permit differs from the permit application, we may provide additional comments at that time.
Further review and any ensuing technical assistance adhere to the process described in the Memorandum of Agreement (MOA) Between the Environmental Protection Agency (EPA), Fish and Wildlife Agency (FWS), and National Marine Fisheries Service (NMFS) Regarding Enhanced Coordination under the Clean Water Act and the Endangered Species Act (66 FR 11202, February 22, 2001); in EPAs 316(b) regulation governing cooling water intakes, 50 CFR Parts 122 and 125, described in 79 FR 48300 (August 15, 2014); in the joint Endangered Species Act Section 7 Consultation: Programmatic Biological Opinion on the U.S. Environmental Protection Agencys Issuance and Implementation of the Final Regulations Section 316(b) of the Clean Water Act (May 19, 2014); and in EPAs instructional memorandum to water division directors (December 11, 2014).
Project Description The Citrus Combined Cycle Station (Citrus) is a nominal 1,640 megawatt natural gas-fired, combined cycle combustion turbine generator facility located adjacent to the Crystal River Energy Complex in Citrus County, Florida. The Citrus facility utilizes two closed-loop mechanical draft cooling towers, which require additional seawater to makeup waters lost through facility operations (e.g., evaporation).
The makeup water intake structure (MWIS) is located at the eastern end of a dredged intake canal that is approximately 140-foot-wide, 20-foot-deep, and extends approximately 9 miles into Crystal Bay and the Gulf of Mexico. The total MWIS design flow is 121 million gallons per day or 167 cubic feet per second. The Citrus intake is approximately 118 feet wide and is comprised of 4-inch on-center spaced bar trash racks in front of four pump bays and seven traveling water screen bays. Screen bays are 9 feet wide with a wetted depth of 21 feet (at normal water elevations), and have 0.375-inch mesh screen panels with a design maximum through-screen velocity of 0.5 feet per second.
3F0124-01 / Enclosure 1 / Page 2 of 3
Species/Critical Habitat Affected We are unsure of how the wastewater discharges may affect the surrounding environment but recommend that Duke Energy continue all required monitoring to ensure no adverse effects. If adverse effects are encountered through monitoring, we request that you notify the National Marine Fisheries Service so that we can aid in developing a solution. We also request that you continue to coordinate with the Florida Sea Turtle Stranding and Salvage Network administered by the Florida Fish and Wildlife Conservation Commission (FWC), and that sea turtles occurring at the MWIS are rescued and transferred to an FWC-authorized sea turtle rehabilitation facility for treatment and recovery.
Our evaluation of the effects of the facilitys cooling water system is that while more than minor detrimental effects to listed species or designated critical habitat in NMFSs jurisdiction may occur, we have determined at this time to recommend no control measures. However, if the conditions of the draft permit differ from the permit application, we may determine that incidental take would occur and recommend control measures in our comments on the draft permit.
Statement of Exemption from the Take Prohibitions Pursuant to the ITS Based on the details in the provided permit application, we do not intend to suggest control measures.
Our conclusion may change if the draft permit differs from the permit application. If we do not suggest control measures, the facility qualifies under the ITS in the May 19, 2014 Biological Opinion for the exemption from the take prohibitions should an unanticipated incidental take occur. The exemption applies only if the permit is issued and the facility operates as described in the permit application. If the permit differs from the permit application or the facility changes its operation from the description in the permit application, the facility will no longer qualify for the exemption in the ITS.
If you have any questions, please contact Joe Heublein on my staff at (727) 209-5962 or joe.heublein@noaa.gov. We look forward to our continued work with you on this project.
Sincerely, Nicholas A. Farmer, Ph.D.
Chief, Species Conservation Branch CC:
Patricia Shaw-Allen, NMFS/OPR 3F0124-01 / Enclosure 1 / Page 3 of 3
Environmental Justice Evaluation BEGINS ON NEXT PAGE 3F0124-01 / Enclosure 2 / Docket No. 50-302
Site Specific Assessment of Environmental and Socioeconomic Indicators Accelerated Decommissioning Partners (ADP) Crystal River Unit 3 Nuclear Plant (CR3)
Crystal River, Florida December 2023 Rev. a The assessment of environmental and socioeconomic indicators around the decommissioning of the Crystal River Unit 3 Nuclear plant (ADP-CR3) that could present environmental justice (EJ) concerns is based on data available through the U.S. Environmental Protection Agency (USEPA), site conditions, and previous experience with EJ issues at other sites.
EJ screening was conducted using USEPA's EJScreen1, which calculates and maps environmental and socioeconomic indicators 2 in percentiles as a means to visualize how the local community compares to other communities within the state and U.S. We screened for environmental and socioeconomic factors that could present EJ issues within the census block groups 3 within a SO-mile radius, as shown in Figure
- 1. The SO-mile radius was previously established by NRC in previous license renewal applications and by Progress Energy in their 2008 Applicant's Environmental Report. EJScreen identifies an area with any of the EJ indexes at or above the 80th percentile and thus these areas should be considered for further review; however, the 80th percentile threshold is not intended to designate an area as an "EJ community." EJScreen provides only screening level indicators, not a determination of EJ concerns.
ADP-CR3 and its associated complex are surrounded by a buffer of undeveloped land, beyond which are residential neighborhoods, followed by moderately industrial and commercial urban areas. Areas utilized for industrial and commercial purposes typically generally have an elevated number of environmental-related risk concerns that may impact nearby susceptible communities. West of the CR-3 complex is the Gulf of Mexico, where no data is collected related to this EJ review.
Within the SO-mile buffer adjacent to ADP CR3, environmental justice indexes show little results for EJ issues above the 80th percentile. Areas where environmental indicators do show elevated EJ concerns are predominantly located in the eastern portions of the assessment radius, including the city of Ocala and the southwest urban areas of Gainesville. An example of this is shown in Figure 2 displaying Air Toxics Cancer Risk. Lower percentiles of the EJ Indexes related to air quality in this region suggest potential impacts to air quality due to increased traffic would not likely impact conditions for employees nor communities adjacent to ADP CR3. Additionally, waste transportation during decommissioning activities is not anticipated to utilize diesel trucking. Similarly, industrial-related pollution sources are not currently a major concern adjacent to ADP CR3, with the nearest Superfund site outside of the assessment area and little to no facilities that handle hazardous wastes. While EJScreen data is limited or unavailable for wastewater discharge, ADP CR3 is anticipated to have no incremental effect on water resources, according to the Progress Electric report, as the project does not involve the management or storage of surface water and does not involve dams, impoundments, or reservoirs.
From a social vulnerability perspective, evaluation of socioeconomic indicators show significant potential vulnerable populations with areas above the 80th percentile distributed throughout the assessment area, as shown in Figure 3. Low income, unemployment, sensitive age populations, and the health disparities of low life expectancy and cancer are disproportionately high in comparison with the rest of the country. While these socioeconomic indicators are elevated within the assessment area, it is 1 What is EJScreen? I USEPA. Available at: https://www.epa.gov/ejscreen/what-ejscreen 2 Overview of Socioeconomic Indicators in EJScreen I USEPA. Available at:
https ://www.epa.gov/ ejscreen/ overview-socioeconomic-ind icators-ejscreen 3 Census block groups typically have a range of 600 to 3,000 people living in them.
3F0124-01 / Enclosure 2 / Page 1 of 4
Environmental and Socioeconomic Indicator Assessment for ADP CR3 Page 2 unlikely these factors are to be impacted further by decommissioning activities related to ADP CR3 due to the nature of the sparse historic and current environmental pollutant sources in the region.
Furthermore, the Crystal River Nuclear waste removal is anticipated to be transported by barge or rail, limiting detrimental impacts to residents as much as possible.
Finally, please note that EJScreen results also show potential concerns for limited broadband access, limited English speaking, and low educational attainment. These critical services gaps can negatively impact the ability of community members to obtain or understand informational outreach and will be taken into consideration should ADP CR3 be required for additional outreach.
Based on this site-specific analysis, it is concluded that the environmental justice impacts from this decommissioning project are SMALL.
llllii 95. 00 percentile 90 - 95 percen ile 80
- 90 percentile 70 - 80 percen ile 60 - 70 percentile 50 - 60 percentile Less than 50 i)ercentile Data not available Gainesvllle 0
20
' 27 Eustis Figure 1. Assessment area for potential environmental justice impacts, the red circle indicating the SO-mile buffer centered on the Crystal River complex.
3F0124-01 / Enclosure 2 / Page 2 of 4
ent for ADP CR3 omic Indicator Assessm ntal and Soc1oecon Environ me Page 3
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Environmental and Socioeconomic Indicator Assessment for ADP CR3 Page 4 Figure 3. Socioeconomic indicator "Over age 64" 3F0124-01 / Enclosure 2 / Page 4 of 4