Text

Post-Shutdown Decommissioning Activities Report
	ML13340A009
Person / Time
Site:	Crystal River
Issue date:	12/02/2013
From:	Elnitsky J; Duke Energy Florida
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML13343A183	List: 3F1213-02, Post-Shutdown Decommissioning Activities Report; ML13343A178;
References
	3F1213-02
	Download: ML13340A009 (39)
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Crystal River Nuclear Plant

@DUKE ENERGY. 15760 W. Power Line Street Crystal River, FL 34428 Docket 50-302 Operating License No. DPR-72 10 CFR 50.82 December 2, 2013 3F1213-02 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Post-Shutdown Decommissioning Activities Report

Reference:

CR-3 to NRC letter dated February 20, 2013, "Crystal River Unit 3 - Certification of Permanent Cessation of Power Operations and that Fuel Has Been Permanently Removed from the Reactor" (ADAMS Accession No. ML13056A005)

Dear Sir:

Pursuant to 10 CFR 50.82(a)(4)(i), Duke Energy Florida, Inc. (DEF) is submitting the Post-Shutdown Decommissioning Activities Report (PSDAR) for Crystal River Unit 3 (CR-3) as an Enclosure to this letter. In the Reference, DEF notified the NRC that CR-3 had removed fuel from the reactor and permanently shut down. In accordance with 10 CFR 50.82(a)(8)(iii), the PSDAR contains a site-specific decommissioning cost estimate.

The PSDAR has been developed consistent with Regulatory Guide 1.185, Revision 1, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report." The CR-3 PSDAR includes a description of the planned decommissioning activities, a schedule for their accomplishment, a site-specific decommissioning cost estimate, and a discussion that provides the basis for concluding that the environmental impacts associated with decommissioning activities will be bounded by appropriate, previously issued, environmental impact statements. The PSDAR also includes a discussion of the schedule and costs associated with the management of spent fuel and site restoration. Funding for irradiated fuel management is being addressed in a separate submittal titled, "Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)."

In accordance with 10 CFR 50.82(a)(4)(i) a copy of the PSDAR is being submitted to the State of Florida.

There are no new regulatory commitments made within this submittal.

If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Regulatory Affairs Manager at (352) 563-4796.

in Elnitsky, Vice President iject Management and Construction JE/drw

Enclosure:

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report xc: NRR Project Manager Regional Administrator, Region I Florida Public Service Commission - Commission Clerk

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 ENCLOSURE CRYSTAL RIVER UNIT 3 POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 1.0 Introduction and Sum mary ............................................................................................... 1 1.1 Introduction ................................................................................................................... 1 1.2 Background .................................................................................................................. 1 1.3 Sum mary of Decom m issioning Alternatives ..................................................................2 2.0 Description of Planned Decom m issioning Activities ......................................................... 4 2.1 Discussion of Decom m issioning Periods ...................................................................... 7 2.1.1 Period 1: Preparations ...........................................................................................7 2.1.2 Period 2: Dorm ancy ............................................................................................... 8

.2.1.3 Period 3: Preparations for Decom m issioning ......................................................... 8 2.1.4 Period 4: Decom m issioning ...................................................................................9 2.1.5 Period 5: Site Restoration .................................................................................... 11 2.2 General Decom m issioning Considerations ................................................................. 12 2.2.1 Major Decom m issioning Activities ........................................................................ 12 2.2.2 Other Decom m issioning Activities ........................................................................ 13 2.2.3 Decontam ination and Dismantlement Activities ................................................... 13 2.2.4 Radioactive W aste Management ......................................................................... 14 2.2.5 Rem oval of Mixed W astes ................................................................................... 14 2.2.6 Site Characterization ........................................................................................... 14 2.2.7 Groundwater Protection and Radiological Decommissioning Records Program.. 14 2.2.8 Changes to Managem ent and Staffing ................................................................. 15 3.0 Schedule of Planned Decom m issioning Activities .......................................................... 16 4.0 Estimate of Expected Decommissioning and Spent Fuel Management Costs ................ 17 5.0 Environmental Im pacts ...................................................................................................22 5.1 Environmental Im pact of CR-3 Decom m issioning ....................................................... 22 5.1.1 Onsite/Offsite Land Use ....................................................................................... 22 5.1.2 W ater Use ...........................................................................................................23 5.1.3 W ater Quality ....................................................................................................... 23 5.1.4 Air Quality ............................................................................................................23 5.1.5 Aquatic Ecology ...................................................................................................24 5.1.6 Terrestrial Ecology ............................................................................................... 24 5.1.7 Threatened and Endangered Species .................................................................25 5.1.8 Radiological ......................................................................................................... 26 5.1.9 Radiological Accidents .........................................................................................27 5.1.10 Occupational Issues ............................................................................................27 5 .1 .1 1 Co st .....................................................................................................................2 8 5.1.12 Socioeconom ics ..................................................................................................28 i Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 5.1.13 Environm ental Justice ..................................................................................... 28 5.1.14 Cultural, Historic, and Archeological Resources ............................................. 29 5.1.15 Aesthetic Issues ............................................................................................. 29 5.1.16 Noise ................................................................................................................... 30 5.1.17 Transportation .................................................................................................. 30 5.1.18 Irreversible and Irretrievable Com m itm ent of Resources ................................ 31 5.2 Environmental Impacts of License Termination - NUREG-1496 ............................. 31 5.3 Discussion of Decom m issioning in the DSEIS ........................................................ 31 5.4 Additional Considerations ....................................................................................... 32 5.5 Conclusions ................................................................................................................ 32 6.0 References ..................................................................................................................... 34 Acronyms AIF Atomic Industrial Forum ALARA As Low As Reasonably Achievable BMP Best Management Practices CFR Code of Federal Regulations CR-3 Crystal River Unit 3 CREC Crystal River Energy Complex DCE Decommissioning Cost Estimate DEF Duke Energy Florida, Inc.

DOE Department of Energy DSEIS Draft Supplemental Environmental Impact Statement (NUREG-1437, Supp. 44)

EPA Environmental Protection Agency FDEP Florida Department of Environmental Protection FPSC Florida Public Service Commission GElS Generic Environmental Impact Statement (NUREG-0586)

GTCC Greater than Class C GW Groundwater ISFSI Independent Spent Fuel Storage Installation LLRW Low-Level Radioactive Waste LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MWt Megawatt-thermal NEI Nuclear Energy Institute NESP National Environmental Studies Project NPDES National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission PSDAR Post-Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor SAR Safety Analysis Report SFP Spent Fuel Pool SSCs Structures, Systems and Components ii Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report

1.0 INTRODUCTION

AND

SUMMARY

1.1 Introduction In accordance with the requirements of Title 10 of the Code of Federal Regulations (CFR) 50.82, "Termination of license," paragraph (a)(4)(i), this report constitutes the Duke Energy Florida, Inc. (DEF) Post-Shutdown Decommissioning Activities Report (PSDAR) for Crystal River Unit 3 (CR-3). This PSDAR contains the following:

1. A description of the planned decommissioning activities along with a schedule for their accomplishment.

2. 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.

3. A site-specific decommissioning cost estimate (DCE), including the projected cost of managing irradiated fuel.

The PSDAR has been developed consistent with Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report," (Reference 1). This report is based on currently available information and the plans discussed herein may be modified as additional information becomes available or conditions change. As required by 10 CFR 50.82(a)(7), DEF will notify the Nuclear Regulatory Commission (NRC) in writing before performing any decommissioning activity inconsistent with, or making any significant schedule change from, those actions and schedules described in the PSDAR, including changes that significantly increase the decommissioning cost.

1.2 Background CR-3 is part of the larger Crystal River Energy Complex (CREC), which is located on the Gulf of Mexico in Citrus County, Florida. DEF is the majority owner of CR3 with minority ownership held by City of Alachua, City of Bushnell, City of Gainesville, City of Kissimmee, City of Leesburg, City of Ocala, Orlando Utilities Commission, Seminole Electric Cooperative, and City of New Smyrna Beach. This site location is approximately 7.5 miles northwest of the City of Crystal River, and 70 miles north of Tampa. In addition to CR-3, other structures on the CREC include four fossil-fueled units, two large cooling towers, coal delivery and storage areas, ash storage area, office buildings, warehouses, barge handling docks, and a railroad. CR-3 uses approximately 27 acres of previously disturbed land within the 1,062 acre developed portion of the 4,738 acre CREC site. CR-3 is located at latitude 280 57' 25.87" north and longitude 820 41' 55.95" west.

CR-3 is a single unit pressurized light-water reactor (PWR) supplied by Babcock & Wilcox.

CR-3 was initially licensed to operate at a maximum of 2,452 megawatt-thermal (MWt). In 1981, 2002, and 2007, the NRC approved three DEF requests to increase the licensed core power level to a maximum power level of 2,609 MWt. The reactor containment structure is a steel-lined, reinforced-concrete structure in the shape of a cylinder and capped with a shallow dome. The walls of the containment structure are approximately 3.5 feet thick. Cooling water for CR-3 is drawn from and returned to the Gulf of Mexico.

A brief history of the major milestones related to CR-3 construction and operational history is as follows:

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report

" Construction Permit Issued: September 25, 1968

" Operating License Issued: January 28, 1977

" Commercial Operation: March 13, 1977

Initial Operating License Expiration: December 3, 2016

Final Reactor Shutdown: September 26, 2009

" Final Removal of Fuel from Reactor Vessel: May 28, 2011 By letter dated February 20, 2013, (Reference 2), DEF provided the NRC with the certification required by 10 CFR 50.82(a)(1)(i) and (ii), that operation had permanently ceased and that all fuel had been permanently removed from the reactor vessel at CR-3. Upon docketing of these certifications pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorized operation of the reactor or emplacement or retention of fuel in the reactor vessel. On March 13, 2013, the NRC acknowledged the DEF certification of permanent cessation of power operation and permanent removal of fuel from the vessel, and that pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorized operation of the reactor or emplacement or retention of fuel in the reactor vessel (Reference 3).

Pursuant to 10 CFR 50.51(b), "Continuation of license," the license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the utilization facility until the Commission notifies the licensee in writing that the license has been terminated.

During the period that the modified license remains in effect, 10 CFR 50.51(b) requires that DEF:

1. Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility including storage, control, and maintenance of the spent fuel in a safe condition.

2. Conduct activities in accordance with all other restrictions applicable to the facility in accordance with NRC regulations and the 10 CFR 50 facility license.

10 CFR 50.82(a)(9) states that power reactor licensees must submit an application for termination of the license at least two years prior to the license termination date and that the application must be accompanied or preceded by a license termination plan to be submitted for NRC approval.

1.3 Summary of Decommissioning Alternatives The NRC has evaluated the environmental impacts of three general methods for decommissioning power reactor facilities in NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors," (GELS) (Reference 4). The three general methods evaluated are summarized as follows:

DECON: The equipment, structures and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

SAFSTOR: After the plant is shutdown and defueled, the facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is 2 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report decontaminated and dismantled at the end of the storage period to levels that permit license termination. During SAFSTOR, a facility is left intact or may be partially dismantled, but the fuel is removed from the reactor vessel and radioactive liquids are drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, thereby reducing the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement.

ENTOMB: Radioactive structures, systems and components (SSCs) are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits termination of the license.

The decommissioning approach that has been selected by DEF for CR-3 is the SAFSTOR method. The primary objectives of the CR-3 decommissioning project are to remove the facility from service, reduce residual radioactivity to levels permitting unrestricted release, restore the site, perform this work safely, and complete the work in a cost effective manner. The selection of a preferred decommissioning alternative is influenced by a number of factors at the time of plant shutdown. These factors include the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of low-level waste disposal facilities, availability of a high-level waste (spent fuel) repository or a Department of Energy (DOE) interim storage facility, regulatory requirements, and public concerns. In addition, 10 CFR 50.82(a)(3) requires decommissioning to be completed within 60 years of permanent cessation of operations.

Under the SAFSTOR methodology, the facility is placed in a safe and stable condition and maintained in that state allowing levels of radioactivity to decrease through radioactive decay, followed by decontamination and dismantlement. After the safe storage period, the facility will be decontaminated and dismantled to levels that permit license termination. In accordance with 10 CFR 50.82(a)(9), a license termination plan will be developed and submitted for NRC approval at least two years prior to termination of the license.

The decommissioning approach for CR-3 is described in the following sections.

" Section 2.0 describes the planned decommissioning activities and the general timing of their implementation.

" Section 3.0 describes the overall decommissioning schedule, including the spent fuel management activities.

" Section 4.0 provides an analysis of expected decommissioning costs, including the costs associated with spent fuel management and site restoration.

" Section 5.0 describes the basis for concluding that the environmental impacts associated with decommissioning CR-3 are bounded by the NRC generic environmental impact statement related to decommissioning.

" Section 6.0 is a list of references.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report

2.0 DESCRIPTION

OF PLANNED DECOMMISSIONING ACTIVITIES DEF is currently planning to decommission CR-3 using a SAFSTOR method. SAFSTOR is broadly defined in Section 1.3 of this report.

Use of the SAFSTOR approach is consistent with the need to effectively manage spent fuel after the facility is permanently shut down. Since DEF will likely be required to manage spent fuel at the site for an extended period of time, a discussion of the irradiated fuel management plan for the site is included in this section. During the initial phase of decommissioning, the plant will be configured to ensure continued safe storage of spent fuel while it remains in the spent fuel pool (SFP), before transfer to an Independent Spent Fuel Storage Installation (ISFSI).

The spent fuel will be stored in the ISFSI until possession is transferred to the DOE.

Tables 2-1 and 2-2 provide summaries of the schedule and costs for decommissioning CR-3.

The major decommissioning periods and the general sequencing of activities that will occur during each period are identified in and are discussed in more detail in the sections that follow.

The decommissioning plan consists of 4 decommissioning periods and multiple sub-periods (associated with 10 CFR 50.75(c) requirements). Spent fuel management activities (associated with 10 CFR 50.54(bb) requirements) are concurrent with the first 2 decommissioning periods.

A site restoration period (representing post-license termination activities) is also included. The site restoration period follows the decommissioning periods sequentially. The periods (and sub-periods) are identified in Table 2-1, along with the start and end dates. The costs of performing the activities associated with each period and sub-period are shown in Table 2-2.

The planning required for each decommissioning activity, including the selection of the process to perform the work, will be performed in accordance with applicable site procedures. No decommissioning activities unique to the site have been identified as necessary, and no activities outside the bounds considered in the GElS have been identified or are anticipated.

Radiological and environmental programs will be maintained throughout the decommissioning process to ensure radiological safety and environmental compliance is maintained. Radiological programs will be conducted in accordance with the facility Technical Specifications, Operating License, Safety Analysis Report (SAR), Radiological Environmental Monitoring Program, and the Offsite Dose Calculation Manual. Environmental programs will be conducted in accordance with applicable requirements and permits.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report Table 2.1 Decommissioning Schedule Summary Duration Decommissioning Periods Start End (years)

Period 1: Planning and Preparations [1] 03 Jun 2013 01 Jul 2015 2.08 Period 2a: Dormancy w/Wet Fuel Storage 01 Jul 2015 13 Aug 2019 4.12 Period 2b: Dormancy w/Dry Fuel Storage 13 Aug 2019 31 Dec 2036 17.39 Period 2c: Dormancy w/No Fuel Storage 31 Dec 2036 23 May 2067 30.39 Period 3a: Site Reactivation 23 May 2067 22 May 2068 1.00 Period 3b: Decommissioning Prep 22 May 2068 21 Nov 2068 0.50 Period 4a: Large Component Removal 21 Nov 2068 03 May 2070 1.45 Period 4b: Plant Systems Removal and Building Remediation 03 May 2070 22 May 2072 2.05 Period 4f: License Termination 22 May 2072 20 Feb 2073 0.75 Period 5b: Site Restoration 20 Feb 2073 21 Aug 2074 1.50 Total 121 _ 61.22

[ While permanent cessation of operations was declared on February 20, 2013, decommissioning costs are accumulated as of June 2013

[21 Columns may not add due to rounding 5 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report Table 2.2 Decommissioning Cost Summary [1]

(thousands of 2013 dollars)

License Spent Fuel Site Decommissioning Periods Termination Management Restoration Period 1: Planning and Preparations [2] 145,653 33,638 Period 2a: Dormancy w/Wet Fuel Storage [3] 28,071 147,032 Period 2b: Dormancy w/Dry Fuel Storage 94,344 84,835 Period 2c: Dormancy w/No Fuel Storage 163,892 -

Period 3a: Site Reactivation 43,152 - 667 Period 3b: Decommissioning Prep 34,626 - 876 Period 4a: Large Component Removal 170,798 - 2,356 Period 4b: Plant Systems Removal and Building 155,222 - 1,397 Remediation Period 4f: License Termination 25,926 Period 5b: Site Restoration 219 - 47,424 Total [41 861,902 265,505151 52,721

[1] Represents the total cost of decommissioning: DEF's share (91.8%), as well as that of the nine minority owners: City of Alachua, City of Bushnell, City of Gainesville, City of Kissimmee, City of Leesburg, City of Ocala, Orlando Utilities Commission, Seminole Electric Cooperative, and City of New Smyrna Beach

[2] Includes site costs (budgets for 2013, 2014 and the first half of 2015), installation of the alternative spent fuel cooling system, shutdown electrical line-up, and removal of legacy waste from the site

[3] Includes site costs to off-load the spent fuel pool to the ISFSI (completed in 2019)

[4] Columns may not add due to rounding

[5] $93.8M in ISFSI capital costs funded from sources outside the decommissioning trust fund are not included in the total.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 2.1 Discussion of Decommissioning Periods A detailed cost estimate was developed to decommission CR-3 under the SAFSTOR alternative. The following narrative describes the basic activities associated with this alternative. The site specific DCE (detailed in Attachment 1) is divided into phases or periods based upon major milestones within the project or significant changes in the projected expenditures.

2.1.1 Period 1: Preparations The NRC defines SAFSTOR as, "A method of decommissioning in which a nuclear facility is placed and maintained in a condition that allows the facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."

The facility is left intact (during the dormancy period), with structures maintained in a sound condition. Systems that are not required to support the spent fuel pool or site surveillance and security are drained, de-energized, and secured. Minimal cleaning/removal of loose contamination and/or fixation and sealing of remaining contamination is performed. Access to contaminated areas is secured to provide controlled access for inspection and maintenance.

Preparations for long-term storage include the revision of technical specifications appropriate to the operating conditions and requirements, a characterization of the facility and major components, and the development of the PSDAR.

The process of placing the plant in safe-storage includes, but is not limited to, the following activities:

" Creation of an organizational structure to support the decommissioning plan and evolving emergency planning and site security requirements.

" Design and installation of an alternate spent fuel cooling system, including air-cooled heat exchangers to be located on the control complex roof and piped into the existing service water system.

" Isolation of the spent fuel pool and fuel handling systems so that safe-storage operations may commence on the balance of the plant.

" Construction of the ISFSI pad and acquisition of the dry fuel storage modules for off-load of the spent fuel pool.

" Removal of systems from service that are no longer required to support site operations or maintenance.

" Processing and disposal of water, filter and treatment media that is not required to support dormancy operations.

" Disposition of legacy waste, including the retired steam generators, reactor vessel closure head and hot leg piping.

" Reconfiguration of ventilation, fire protection, electric power, lighting, and other plant systems needed to support long-term storage and periodic plant surveillance and maintenance.

" Cleaning or fixing loose surface contamination to facilitate future building access and plant maintenance.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report

" Performing an interim radiation survey of the plant, posting caution signs and establishing access requirements, where appropriate.

" Posting and/or cordoning off high contamination / high radiation areas.

" Reconfiguring security boundaries and surveillance systems, as required.

2.1.2 Period 2: Dormancy Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. Resident maintenance personnel perform equipment maintenance, inspection activities, routine services to maintain safe conditions, adequate lighting, heating, and ventilation, and periodic preventive maintenance on essential site services.

An environmental surveillance program will be carried out during the dormancy period to monitor and control releases of radioactive material to the environment. Appropriate emergency procedures are established and initiated for potential releases that exceed prescribed limits.

The environmental surveillance program constitutes an abbreviated version of the program in effect during normal plant operations.

Security during the dormancy period will be conducted primarily to safeguard the spent fuel while on site and prevent unauthorized entry. The security fence, sensors, alarms, and other surveillance equipment provide security. Fire and radiation alarms are also monitored and maintained.

Once the ISFSI is constructed (estimated in late 2016), the spent fuel will be transferred from the spent fuel pool to horizontal storage modules located on the ISFSI pad. Spent fuel transfer is expected to be complete by January 2019.

For planning purposes, DEF's current spent fuel management plan for the CR-3 spent fuel is based, in general, upon the following projections: 1) a 2032 start date for the DOE initiating transfer of commercial spent fuel to a federal facility, 2) a corresponding 2035 date for beginning to remove spent fuel from CR-3, and 3) a 2036 completion date for removal of all CR-3 spent fuel, although transfer could occur earlier if the DOE is successful in implementing its current strategy for the management and disposal of spent fuel. The ISFSI will be secured for long-term storage and decommissioned along with the power block structures in Period 4.

2.1.3 Period 3: Preparations for Decommissioning CR-3 is currently expected to remain in safe-storage until 2067, at which time preparations for decommissioning would commence.

Prior to the commencement of decommissioning operations, preparations are undertaken to reactivate site services and prepare for decommissioning. Preparations include engineering and planning, a detailed site characterization, and the assembly of a decommissioning management organization. Final planning for activities and the writing of activity specifications and detailed procedures are also initiated at this time.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report At least two years prior to the anticipated date of license termination, a License Termination Plan (LTP) is required. Submitted as a supplement to the SAR or its equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local hearing. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission.

2.1.4 Period 4: Decommissioning This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures, including the successful termination of the 10 CFR 50 operating license. Although the initial radiation levels due to 60CO will decrease during the dormancy period, the internal components of the reactor vessel will still exhibit sufficiently high radiation dose rates to require remote sectioning under water due to the presence of long-lived radionuclides such as 94 Nb, 59Ni, and 63 Ni. Portions of the biological shield will also be radioactive due to the presence of activated trace elements with long half-lives (152 Eu and 154 Eu). Decontamination will require controlled removal and disposal. It is assumed that radioactive corrosion products on inner surfaces of piping and components will not have decayed to levels that will permit unrestricted use or allow conventional removal.

These systems and components will be surveyed as they are removed and disposed of in accordance with the existing radioactive release criteria.

Significant decommissioning activities in this phase include:

o Reconfiguration and modification of site structures and facilities, as needed, to support decommissioning operations. This may include establishing a centralized processing area to facilitate equipment removal and component preparation for offsite disposal.

Modifications may also be required to the reactor building to facilitate access of de-construction equipment, support the segmentation of the reactor vessel internals, and for large component extraction.

o Design and fabrication of temporary and permanent shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.

o Procurement (lease or purchase) of shipping canisters, cask liners, and industrial packages for the disposition of low-level radioactive waste (LLRW).

o Decontamination of components and piping systems, as required, to control (minimize) worker exposure.

o Removal of piping and components no longer essential to support decommissioning operations.

o Removal of control rod drive housings and the head service structure from the reactor vesselhead.

o Removal and segmentation of the plenum assembly. Segmentation will maximize the loading of the shielded transport casks (i.e., by weight and activity). The operations will be conducted under water using remotely operated tooling and contamination controls.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report

" Disassembly and segmentation, if necessary, of the remaining reactor internals, including the core former and baffles and lower core support assembly. Depending on packaging, some material may exceed Class C disposal requirements. Any such material will be packaged in modified fuel storage canisters for transfer to the DOE. In the unlikely event that GTCC waste was unable to be shipped to DOE during decontamination and demolition activities, it would be safely stored on the ISFSL

" Removal of the reactor vessel. If segmented, a shielded. platform will be installed for segmentation as cutting operations will be performed in-air using remotely operated equipment within a contamination control envelope. The water level will be maintained just below the cut to minimize the working area dose rates. Segments will be transferred in-air to containers that are stored under water, for example, in an isolated area of the refueling canal.

" Removal of the activated and contaminated portions of the concrete biological shield and accessible contaminated concrete surfaces. If dictated by the steam generator and pressurizer removal scenarios, those portions of the associated D-rings necessary for access and component extraction will be removed.

" Removal of the steam generators and pressurizer for controlled disposal. The generators will be moved to an onsite processing center and prepared for transport to the waste processor. To facilitate transport, the generators will be cut in half, across the tube bundle.

The exposed ends will be capped and sealed. The pressurizer will be disposed of intact.

" Removal of remaining plant systems and associated components as they become non-essential to the decommissioning program or worker health and safety (e.g., waste collection and treatment systems, electrical power and ventilation systems).

" Removal of the steel liners from the refueling canal, disposing of the activated and contaminated sections as radioactive waste. Removal of any activated/contaminated concrete.

" Surveys of the decontaminated areas of the reactor building.

" Remediation and removal of the contaminated equipment and material from the auxiliary building and any other contaminated area. Radiation and contamination controls will be utilized until residual levels indicate that the structures and equipment can be released for unrestricted access and conventional demolition. This activity may necessitate the dismantling and disposition of most of the systems and components (both clean and contaminated) located within these buildings. This activity facilitates surface decontamination and subsequent verification surveys required prior to obtaining release for demolition.

" Routing of material removed in the decontamination and dismantling to a central processing area. Material certified to be free of contamination will be released for unrestricted disposition, e.g., as scrap, recycle, or general disposal. Contaminated material will be characterized and segregated for additional offsite processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and/or packaged for controlled disposal at a low-level radioactive waste disposal facility.

" Remediation of the West Settling Pond to meet the unrestricted release criteria in 10 CFR 20.1402. The DCE assumes that 500 cubic yards of contaminated soil will be shipped offsite as LLRW for disposal.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report o Removal of contaminated underground piping. The DCE assumes that the Station Drain Tank line and the approximately 1,000 foot long nitrogen line will be removed in order to meet license termination criteria.

Incorporated into the LTP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)." This document incorporates the statistical approaches to survey design and data interpretation used by the Environmental Protection Agency (EPA). It also identifies state-of-the-art, commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the surveys are complete, the results are provided to the NRC in a format that can be verified. The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on the requested change to the operating license.

The NRC will terminate the operating license if it determines that site remediation has been performed in accordance with the LTP, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release.

2.1.5 Period 5: Site Restoration The efficient removal of the contaminated materials at the site may result in damage to many of the site structures. Blasting, coring, drilling, and the other decontamination activities can substantially damage power block structures, potentially weakening the footings and structural supports. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. Dismantling site structures with a work force already mobilized is more efficient and less costly than if the process is deferred.

Consequently, this study assumes that site structures addressed by this analysis are removed to a nominal depth of three feet below the top grade of the embankment, wherever possible.

This assumption was applied to the disposition of all CR-3 facilities on the berm and, as a result, the general topography of the berm will be retained at the conclusion of site restoration.

The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can be established for erosion control. Site areas affected by the dismantling activities are restored and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials.

Non-contaminated concrete rubble produced by demolition activities is processed to remove reinforcing steel and miscellaneous embedments. The processed material will then be used on site to backfill foundation voids. Excess non-contaminated materials will be trucked to an offsite area for disposal as construction debris.

Remediation of hazardous constituents will also be conducted during the site restoration phase.

Soil containing lead residue will be excavated from the Firing Range and disposed of offsite.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 2.2 General Decommissioning Considerations 2.2.1 Major Decommissioning Activities As defined in 10 CFR 50.2, "Definitions," a "major decommissioning activity" is "any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than class C waste in accordance with § 61.55." The following discussion provides a summary of the major decommissioning activities currently planned for CR-3. These activities are envisioned to occur in Period 4 however, the schedule may be modified as conditions dictate.

Prior to starting a major decommissioning activity, the affected components will be surveyed and decontaminated, as required, in order to minimize worker exposure, and a plan will be developed for the activity. Shipping casks and other equipment necessary to conduct major decommissioning activities will be designed and procured.

The initial major decommissioning activities will focus on the removal, packaging and disposal of piping and components that are no longer essential to support decommissioning operations.

Additional systems and associated components will be removed as they become non-essential to the reactor vessel removal operations, related decommissioning activities, or worker health and safety.

The initial major decommissioning activity inside containment will be the removal, packaging, and disposal of the control rod drive housings from the reactor vessel head. The reactor vessel insulation will be removed, followed by the removal and disposal of the reactor coolant piping and pumps.

Following reactor vessel and cavity reflood, the reactor vessel internals will be removed from the reactor vessel and segmented, if necessary, for packaging or to separate greater than Class C (GTCC) waste. The internals comprising the core shroud, core support structure, fuel guide plate, and upper portions of the incore thimble guide tubes may need to be treated as GTCC waste, in which case the components will be segmented and packaged into dry shielded containers for transfer to the DOE. Using this approach, the internals will be packaged and disposed of independent of the reactor vessel. When the internals segmentation effort is completed, the reactor vessel and cavity will be drained and any remaining debris removed.

Removal of the reactor vessel and vessel closure head follows the removal of the reactor internals. Without the internals present, several options are available for the removal and disposal of the reactor vessel: segmentation, sectioning into larger pieces, or disposal as an intact package. It is likely that the components would be removed by sectioning or segmenting performed remotely in-air using a contamination control envelope. Vessel sectioning or segmenting will permit a substantial portion of the waste to be sent to a waste re-processor instead of a near surface disposal site. Any segments that need to be treated as GTCC will be placed into shielded canisters and transferred to the DOE.

Additional major decommissioning activities that would be conducted include the removal and disposal of the steam generators, pressurizer, spent fuel storage racks and spent fuel bridge crane. The dismantling of the containment structure would be undertaken as part of the reactor building demolition.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 2.2.2 Other Decommissioning Activities Secondary side piping and components in the intermediate building and turbine building may require disposal as LLRW due to steam generator tube leaks during operation. The DCE assumes that portions of the steam system will be dispositioned as LLRW.

2.2.3 Decontamination and Dismantlement Activities The objectives of the decontamination effort are two-fold. The first objective is to reduce radiation levels throughout the facility in order to minimize personnel exposure during dismantlement. This objective will be achieved by allowing radioactive decay during the SAFSTOR period, thereby reducing the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement.

The second objective is to clean as much material as possible to unrestricted use levels, thereby permitting non-radiological demolition and disposal and minimizing the quantities of material that must be disposed of by burial as radioactive waste. The second objective will be achieved by decontaminating structural components including steel framing and concrete surfaces. The methods to accomplish this are typically mechanical, requiring the removal of the surface or surface coating, and are used regularly in industrial and contaminated sites. The need to decontaminate SSCs will be determined by the schedule to dismantle them and by plant conditions.

The decontamination and/or dismantlement of contaminated SSCs may be accomplished by decontamination in place, decontamination and dismantlement, or dismantlement and disposal.

A combination of these methods may be utilized to reduce contamination levels, worker radiation exposures, and project costs. The methods chosen will be those deemed most appropriate for the particular circumstances. Material below the applicable radiological limits will be released for unrestricted disposition (e.g., scrap, recycle, or general disposal). Radioactively contaminated or activated materials will be removed from the site as necessary to allow the site to be released for unrestricted use.

LLRW will be processed in accordance with plant procedures and existing commercial options.

Contaminated material will be characterized and segregated for additional onsite decontamination or processing, offsite processing (e.g., disassembly, chemical cleaning, volume reduction, waste treatment, etc.), and/or packaged for controlled disposal at a LLRW disposal facility.

Contaminated concrete and structural steel components will be decontaminated and removed, as required, in order to gain access to contaminated and uncontaminated systems and components. After the systems and components are removed and processed as described above, the remaining contaminated concrete and structural steel components will be decontaminated and/or removed. Contaminated concrete will be packaged and shipped to a LLRW disposal facility. Contaminated structural steel components may be removed to a processing area for decontamination, volume reduction, and packaging for shipment to a processing facility or to a LLRW disposal facility, as necessary.

Buried and imbedded contaminated components (e.g., piping, drains, etc.) will be decontaminated in place or excavated and decontaminated. Appropriate contamination controls will be employed to minimize the spread of contamination and to protect personnel.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 2.2.4 Radioactive Waste Management A major component of the total cost of decommissioning CR-3 is the cost of packaging and disposing of SSCs, contaminated soil, resins, water, and other plant process liquids. A waste management plan will be developed to incorporate the most cost effective disposal strategy, consistent with regulatory requirements for each waste type. Currently, Class A LLRW can be disposed of at the Energy Solutions facility located in Clive, Utah. Also, Class B and C LLRW may be disposed of at the Waste Control Specialists site in Andrews County, Texas. If other licensed LLRW facilities become available in the future, DEF may choose to use them as well.

The waste management plan will be based on the evaluation of available methods and strategies for processing, packaging, and transporting radioactive waste in conjunction with the available disposal facility options and associated waste acceptance criteria.

2.2.5 Removal of Mixed Wastes Mixed wastes and mixed wastes generated during decommissioning, if any, will be managed in accordance with applicable Federal and State regulations.

Mixed wastes from CR-3 will be transported by authorized and licensed transporters and shipped to authorized and licensed facilities. Iftechnology, resources, and approved processes are available, the processes will be evaluated to render the mixed waste non-hazardous.

2.2.6 Site Characterization During the decommissioning process, a site characterization will be performed in which radiological, regulated, and hazardous wastes will be identified, categorized, and quantified.

Surveys will be conducted to establish the contamination and radiation levels throughout the plant. This information will be used in developing procedures to ensure that hazardous, regulated, and radiologically contaminated areas are removed and to ensure that worker exposure is controlled. Surveys of selected outdoor areas will also be performed including surveys of soil and groundwater near the plant. As decontamination and dismantlement work proceeds, surveys will be conducted to maintain the site characterization current and to ensure that decommissioning activities are adjusted accordingly.

An activity level calculation of the reactor internals, the reactor vessel, and the biological shield wall will be performed as part of the site characterization. Using the results of this analysis, these components will be classified in accordance with 10 CFR 61, "Licensing requirements for land disposal of radioactive waste." The results of the analysis will form the basis for the detailed plans for their packaging and disposal.

2.2.7 Groundwater Protection and Radiological Decommissioning Records Program A groundwater (GW) protection program exists at CR-3 in accordance with the Nuclear Energy Institute (NEI) Technical Report 07-07, "Industry Groundwater Protection Initiative - Final Guidance Document." A site hydrology study was completed as part of this initiative. Thirteen GW monitoring wells were installed around the plant to identify any leakage and transport of radiological contaminants. Trace amounts of tritium, attributed to a 1998 drain line leak, have been detected in some of the GW monitoring wells located on the southwest side of the plant.

GW monitoring well #5 registered the highest levels of tritium; however, none of the samples exceeded the 20,000 pCi/L drinking water standard in 40 CFR 141.66 and 62-550.310(6)(b) of 14 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report the Florida Administrative Code. The measured tritium concentration in GW monitoring well #5 is currently a factor of 40 below the EPA and the Florida Department of Environmental Protection (FDEP) drinking water limit. Given this concentration and a half-life of 12.3 years, no tritium remediation is required at the end of the SAFSTOR period. The GW protection program is directed by procedures and will be maintained during decommissioning.

DEF will also continue to maintain the existing radiological decommissioning records program required by 10 CFR 50.75(g). The program is directed by procedures. None of the events noted in 10 CFR 50.75(g) indicate the presence of long-lived radionuclides in sufficient concentrations to preclude unrestricted release under 10 CFR 20.1402, "Radiological criteria for unrestricted use," at the end of the SAFSTOR period.

2.2.8 Changes to Management and Staffing Throughout the decommissioning process, plant management and staffing levels will be adjusted to reflect the ongoing transition of the site organization.

Revision 0 15 15 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 3.0 SCHEDULE OF PLANNED DECOMMISSIONING ACTIVITIES DEF intends to pursue the decommissioning of CR-3 utilizing a SAFSTOR methodology. The SAFSTOR method involves removal of radioactive or activated material from the site following a period of dormancy. Work activities associated with the planning and preparation period began after the plant was permanently shut down. The schedule of spent fuel management and decommissioning activities is provided in Table 2-1. Additional detail is provided in Section 4 of .

The schedule recognizes that spent fuel will be retained in the ISFSI until it can be ultimately transferred to the DOE.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 4.0 ESTIMATE OF EXPECTED DECOMMISSIONING AND SPENT FUEL MANAGEMENT COSTS 10 CFR 50.82(a)(8)(iii) requires that a site-specific DCE be prepared and submitted within two years following permanent cessation of operations. 10 CFR 50.82(a)(4)(i) requires that the PSDAR contain a site-specific DCE, including the projected cost of managing irradiated fuel.

TLG Services, Inc. has prepared a site-specific decommissioning cost analysis for CR-3, which also provides projected costs of managing spent fuel, as well as non-radiological decommissioning and site restoration costs, accounted for separately. The site-specific DCE is provided in Attachment 1 and fulfills the requirements of 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii). A summary of the site-specific DCE and projected cost of managing spent fuel is provided in Table 2-2.

The methodology used by TLG Services, Inc. to develop the site-specific DCE follows the basic approach originally advanced by the Atomic Industrial Forum (AIF) in its program to develop a standardized model for decommissioning cost estimates. The results of this program were published as AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," (Reference 5). The AIF report presents a unit cost factor method for estimating direct activity costs, simplifying the estimating process. The unit cost factors used in the study reflect the latest available data, at the time of the study, concerning worker productivity during decommissioning.

10 CFR 50.82(a)(6)(iii) states that, "Licensees shall not perform any decommissioning activities," as defined in 10 CFR 50.2 that, "Result in there no longer being reasonable assurance that adequate funds will be available for decommissioning." Because adequate funding exists for decommissioning, as indicated in Table 4, no such activities have been identified. Funding for irradiated fuel management is being addressed in a separate titled, "Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb).

10 CFR 50.82(a)(8)(iv) states that, "For decommissioning activities that delay completion of decommissioning by including a period of storage or surveillance, the licensee shall provide a means of adjusting cost estimates and associated funding levels over the storage or surveillance period." Consistent with Regulatory Guide 1.159 (Reference 6), DEF will update the CR-3 DCE as needed. As an electric utility as defined in 10 CFR 50.2, DEF has the means of adjusting funding levels as necessary through rates approved by the Florida Public Service Commission. The other CR-3 minority owners, as municipalities and cooperatives that establish their own rates, also have the means of adjusting funding levels as necessary.

Financial Assurance DEF intends to fund the expenditures for license termination from the decommissioning trust fund currently held by DEF, as well as the nine minority owners. The aggregate trust fund balance for CR-3 was approximately $778.565 million. The total includes DEF's share (91.8%),

11 1

contributions from the nine joint owner participants, as well as that of the City of Tallahassee.

Total decommissioning funds available include DEF's share (91.8%) as well as that of the nine minority owners: City of Alachua, City of Bushnell, City of Gainesville, City of Kissimmee, City of Leesburg, City of Ocala, Orlando Utilities Commission, Seminole Electric Cooperative, City of New Smyrna Beach, and a former owner: City of Tallahassee 17 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report As shown in Table 4, the current trust funds are sufficient to accomplish the intended tasks and terminate the operating license for CR-3. DEF's nuclear decommissioning trust fund holds funds collected from ratepayers pursuant to orders of the Florida Public Service Commission (FPSC),

based on site-specific cost estimates that include radiological decommissioning (license termination), spent fuel management, and site restoration. Although DEF has not previously set up subaccounts allocating funds to these activities, a recent FPSC order confirms that the accumulated funds must be allocated to each of these activities in accordance with the percentage assigned to each category in the most recent cost study, or update thereto, approved by the FPSC (Reference 14). The FPSC Order, however, declined to restrict funds allocated to spent fuel management or site restoration from being available to pay for radiological decommissioning.

The analysis shows a surplus in the fund at the completion of decommissioning. This surplus could be made available to fund other activities at the site (e.g., spent fuel management and/or restoration activities), recognizing that DEF would need to make the appropriate submittals for an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report TABLE 4 FUNDING REQUIREMENTS FOR LICENSE TERMINATION (thousands, dollars)

Basis Year 2013 Fund Balance $778,565 (thousands)

Annual Escalation 0.00%

Annual Earnings 1.65%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 1.65%

Escalation Cost Escalated at 0% (minus expenses)

Year (thousands) (thousands) (thousands) 2013 33,652 33,652 744,912 2014 67,500 67,500 689,703 2015 47,935 47,935 653,148 2016 6,831 6,831 657,094 2017 6,812 6,812 661,124 2018 6,812 6,812 665,220 2019 6,275 6,275 669,921 2020 5,437 5,437 675,537 2021 5,422 5,422 681,262 2022 5,422 5,422 687,080 2023 5,422 5,422 692,995 2024 5,437 5,437 698,993 2025 5,422 5,422 705,104 2026 5,422 5,422 711,316 2027 5,422 5,422 717,631 2028 5,437 5,437 724,035 2029 5,422 5,422 730,559 2030 5,422 5,422 737,191 2031 5,422 5,422 743,933 2032 5,437 5,437 750,771 2033 5,422 5,422 757,736 2034 5,422 5,422 764,817 2035 5,422 5,422 772,014 2036 5,437 5,437 779,316 2037 5,390 5,390 786,785 2038 5,390 5,390 794,377 2039 5,390 5,390 802,094 2040 5,404 5,404 809,925 19 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report TABLE 4 (continued)

FUNDING REQUIREMENTS FOR LICENSE TERMINATION (thousands, dollars)

-Basis Year 2013

-Fund Balance $778,565 (thousands)

-Annual Escalation 0.00%

-Annual Earnings 1.65%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 1.65%

Escalation Cost Escalated at 0% (minus expenses)

Year (thousands) (thousands) (thousands) 2041 5,390 5,390 817,899 2042 5,390 5,390 826,004 2043 5,390 5,390 834,244 2044 5,404 5,404 842,604 2045 5,390 5,390 851,117 2046 5,390 5,390 859,771 2047 5,390 5,390 868,567 2048 5,404 5,404 877,494 2049 5,390 5,390 886,583 2050 5,390 5,390 895,822 2051 5,390 5,390 905,214 2052 5,404 5,404 914,745 2053 5,390 5,390 924,449 2054 5,390 5,390 934,312 2055 5,390 5,390 944,339 2056 5,404 5,404 954,516 2057 5,390 5,390 964,876 2058 5,390 5,390 975,406 2059 5,390 5,390 986,111 2060 5,404 5,404 996,977 2061 5,390 5,390 1,008,038 2062 5,390 5,390 1,019,281 2063 5,390 5,390 1,030,709 2064 5,404 5,404 1,042,311 2065 5,390 5,390 1,054,120 2066 5,390 5,390 1,066,123 2067 28,461 28,461 1,055,253 2068 64,677 64,677 1,007,988 2069 118,071 118,071 906,549 20 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report TABLE 4 (continued)

FUNDING REQUIREMENTS FOR LICENSE TERMINATION (thousands, dollars)

Basis Year 2013 Fund Balance $778,565 (thousands)

Annual Escalation 0.00%

Annual Earnings 1.65%

A B C Decommissioning License Escalated License Trust Fund Termination Termination Cost Escalated at 1.65%

Escalation Cost Escalated at 0% (minus expenses)

Year (thousands) (thousands) (thousands) 2070 89,757 89,757 831,751 2071 75,541 75,541 769,933 2072 50,584 50,584 732,054 2073 4,857 4,857 739,276 2074 93 93 751,381 Total 861,902 861,902 Notes:

1. Total costs reported (i.e., there is no cost allocation by ownership share)

2. The City of Tallahassee funds can only be used for License Termination activities per NRC Order (Accession No. ML020670117) dated September 8,1999

3. Aggregate balance, as of September 30, 2013, used as year-end 2013 balance Calculations:

Column B (A)*(l +.00) (escalation year - 2013) or for 0%, B =A Column C (Previous year's fund balance) * (1 + .0165) - B (escalation year's decommissioning expenditures) 21 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 5.0 ENVIRONMENTAL IMPACTS 10 CFR 50.82(a)(4)(i) requires that the PSDAR include, "...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." The following discussion provides the reasons for reaching this conclusion and is based on two previously issued environmental impact statements:

1. NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors," Final Report (Reference 4) (Referred to as the GELS).

2. NUREG-1496, "Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities,"

(Reference 7).

In evaluating whether the impacts in these previously issued environmental impact statements are bounding, information from NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 44, Regarding Crystal River Unit 3 Nuclear Generating Plant," Draft Report for Comment (Reference 8) (Referred to as the DSEIS) was also considered.

5.1 Environmental Impact of CR-3 Decommissioning The following is a summary of the reasons for reaching the conclusion that the environmental impacts of decommissioning CR-3 are bounded by the GElS. Each environmental impact standard in the GElS is listed along with a summary as to why DEF concludes the GElS analysis bounds the impacts of CR-3 decommissioning on that standard. As a general matter, CR-3 is smaller than the reference PWR used in NUREG-0586 2 to evaluate the environmental impacts of decommissioning, and is therefore bounded by those assessments. Further, no unique site-specific features or unique aspects of the planned decommissioning have been identified.

5.1.1 Onsite/Offsite Land Use DEF does not anticipate any changes in land use beyond the site boundary during decommissioning. CR-3 has sufficient area onsite that has been previously disturbed (due to construction or operations activities) for use during decommissioning. Construction activities that would disturb greater than one acre of soil require application and approval from the Florida Department of Environmental Protection (FDEP) prior to disturbing the soil. Construction projects are required to control sediment and erosion effect on water course and wetlands. The GElS concluded that the impacts on land use are not detectable or small for facilities having only onsite land use changes as a result of large component removal, structure dismantlement, and low level waste packaging and storage. CR-3 will be able to conduct all of these decommissioning activities on previously disturbed land. Therefore, DEF concludes that the impacts of CR-3 decommissioning on onsite/offsite land use are bounded by the previously issued GElS.

2 The reference PWR evaluated in NUREG-0586 was the Trojan Plant with a power level of 3,411 MWt (Reference 4), while the maximum power level for CR-3 was 2,609 MWt (see Section 1.3).

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 5.1.2 Water Use After plant shutdown, the operational demand for circulating water is eliminated. Additionally, makeup water and raw water use decreases dramatically. During Period 1, the demand for raw water will continue to decrease as the SFP heat load declines due to radioactive decay. Prior to entering Period 2, the need for raw water for cooling purposes will be eliminated by the installation of an alternate spent fuel cooling system. During plant shutdown, the use of potable water will also decrease commensurate with the expected decrease in plant staffing levels. For these reasons, the GEIS concluded that water use at decommissioning nuclear reactor facilities is significantly smaller than water use during operation.

The GEIS also concluded that water use during the decontamination and dismantlement phase will be greater than that during the storage phase. There are no unique aspects associated with the decommissioning of CR-3 and water use for such activities as flushing piping, hydrolazing, dust abatement, etc. Consequently, CR-3 water use impacts were addressed by the evaluation of the reference facility in the GEIS. Therefore, DEF concludes that the impacts of CR-3 decommissioning on water use are bounded by the previously issued GEIS.

5.1.3 Water Quality This section considers water quality impacts of non-radioactive material for both surface and groundwater during the decommissioning process. Table E-3 of the GEIS identifies decommissioning activities that may affect water quality. These activities include system deactivation activities (draining, flushing, and liquid processing) as well as facility decontamination and dismantlement activities (water spraying and rubblization). The GEIS also emphasizes the need to minimize water infiltration during the SAFSTOR period.

Programs and processes designed to minimize, detect, and contain spills will be maintained throughout the decommissioning process. Federal, state and local regulations and permits pertaining to water quality will remain in effect and no significant changes to water supply reliability are expected. The National Pollutant Discharge Elimination System (NPDES) permit, which regulates surface water discharges from the site, will remain in place. Also during the planning and dormancy periods, storm water runoff and drainage paths will be maintained in their current configuration. Industrial Waste Permit FLA016960 requires periodic GW monitoring in the vicinity of the percolation pond system (Reference 8). The site-specific estimate includes costs for periodic roof maintenance that will direct runoff to designed drainage paths and not through the structures themselves. Therefore, DEF concludes that the impacts of CR-3 decommissioning on water quality are bounded by the previously issued GEIS.

5.1.4 Air Quality Title V Air Operations Permit 01 70004-035-AV was issued by the FDEP and regulates air emission sources at CR-3. This permit will remain in place during decommissioning. If new sources of air emissions are added or changed at the facility to support this process, the permit will be modified as required. As new regulations are issued that impact these sources, these requirements will be addressed at the station. In addition, there are various other regulations that apply to air quality including hazardous air pollutants and indoor air quality. There are many types of decommissioning activities that have the potential to affect air quality. These activities are listed in Section 4.3.4.3 of the GEIS. Based on the decommissioning activities delineated in Section 2, DEF does not anticipate any activities beyond those listed in the GEIS 23 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report that could potentially affect air quality. Therefore, DEF concludes that the impacts of CR-3 decommissioning on air quality are bounded by the previously issued GEIS.

5.1.5 Aquatic Ecology Aquatic ecology encompasses the plants and animals in Crystal Bay which is a shallow estuarine embayment of the Gulf of Mexico. Aquatic ecology also includes the interaction of those organisms with each other and the environment. The GEIS evaluates both the direct and indirect impacts from decommissioning on aquatic ecology. Appendix E of the GEIS describes the qualitative process for evaluating these potential environmental impacts.

Direct impacts can result from activities such as the removal of shoreline structures or the active dredging of canals. CR-3's shoreline structures are similar to the plants listed in Table E-2 of the GEIS and there are no apparent discriminators based on the salient characteristics (size and location) listed in Table E-5 of the GEIS. Removal of the intake and discharge facilities as well as other shoreline structures will be conducted in accordance with FDEP permits and best management practices (BMP) will be used. Intake canal dredging will no longer be required due to the diminished residual heat removal requirements and the eventual relocation of the spent fuel to the ISFSL DEF does not anticipate disturbance of lands beyond the current operational areas of the plant, so there should not be any new impacts to aquatic ecology from runoff associated with land disturbance activities. Additionally, any significant potential for sediment runoff or erosion on disturbed areas will be controlled. Also as discussed in Section 5.1.2, the need for raw water for cooling purposes will be eliminated by the installation of an alternate spent fuel cooling system.

This will decrease the potential impacts from impingement and entrainment of aquatic species from what was considered in the GEIS. Therefore, DEF concludes that the impacts of CR-3 decommissioning on aquatic ecology are bounded by the previously issued GEIS.

5.1.6 Terrestrial Ecology Terrestrial ecology considers the plants and animals in the vicinity of CR-3 as well as the interaction of those organisms with each other and the environment. Evaluations of impacts to terrestrial ecology are usually directed at important habitats and species, including plant and animals that are important to industry, recreational activities, the area ecosystems, and those protected by endangered species regulations and legislation. The GEIS evaluates the potential impacts from both direct and indirect disturbance of terrestrial ecology. Appendix E of the GEIS describes the qualitative process for evaluating these potential environmental impacts.

Direct impacts can result from activities such as clearing native vegetation or filling a wetland.

DEF does not anticipate disturbing habitat beyond the operational areas of the plant. All dismantlement, demolition, and waste staging activities are envisioned to be conducted within the industrial area of the site. An objective of new facility construction, such as the ISFSI, will be to reuse previously disturbed land. Also the FDEP controls significant impacts to the environment through regulation of construction activities.

Indirect impacts may result from effects such as erosional runoff, dust or noise. Construction activities that would disturb greater than one acre of soil require application and approval from the FDEP prior to disturbing the soil. Construction projects are required to control sediment and the effects of erosion. Fugitive dust emissions will be controlled through the judicial use of 24 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report water spraying. The basis for concluding that the environmental impacts of noise are bounded by the GElS is discussed in Section 5.1.16.

The GElS concludes that if BMP are used to control indirect disturbances and habitat disturbance is limited to operational areas, the potential impacts to terrestrial ecology are small.

As discussed above, there are no unique disturbances to the terrestrial ecology anticipated during the decommissioning of CR-3. Therefore, DEF concludes that the impacts of CR-3 decommissioning on terrestrial ecology are bounded by the previously issued GELS.

5.1.7 Threatened and Endangered Species Aquatic species that are Federally-listed as threatened or endangered and that occur in the vicinity of CR-3 are limited to two species of fish: Gulf sturgeon, smalltooth sawfish; five species of sea turtles: green turtle, hawksbill, Kemp's ridley, leatherback, loggerhead; one crocodilian species: American alligator, and one marine mammal: Florida manatee.

A total of 32 terrestrial species (18 plants and 14 animals) that are listed by the State of Florida as endangered, threatened, or species of special concern are known to occur in Citrus County, the location of the CREC. However, there are only two State-listed species that are known to occur on the CREC site - the bald eagle (threatened) and the wood stork (endangered), while an additional three State-listed species can potentially occur at the CREC site - the gopher tortoise, the eastern indigo snake, and the piping plover.

The GElS does not make a generic determination on the impact of decommissioning on threatened and endangered species. Rather it concludes that the adverse impacts and associated significance of the impacts must be determined on a site-specific basis.

With respect to the threatened and endangered aquatic species, the environmental impacts during decommissioning are expected to be minimal. Removal of shoreline structures will be conducted in accordance with FDEP permits and BMP will be used. Intake canal dredging is no longer expected to occur due to the diminished heat load. Shutting off the Circulating Water System reduces the effects of impingement, entrainment, and thermal discharges on aquatic species. After the alternate spent fuel pool cooling system is installed, no reliance will be placed on the Gulf of Mexico to cool CR-3 heat loads and the Raw Water System will no longer function in this capacity. This will further reduce the impacts of impingement, entrainment, and thermal discharges. One potential adverse impact from discontinuing the use of the CR-3 Circulating and Raw Water Systems may be the reduction of a thermal refuge for manatees in the discharge canal when Crystal River Units 1 and 2 are not operating in the winter months.

The environmental impacts during decommissioning are expected to be minimal on threatened and endangered terrestrial species. DEF does not anticipate disturbing habitat beyond the operational areas of the plant for decommissioning and construction activities. Major construction activities are permitted by the FDEP and are required to control sediment and the effects of erosion. Additionally, DEF project management standard PJM-0001 1-ENTSTD, "Project Environmental, Health and Safety Management Standard," requires that significant project activities undergo an environmental review prior to authorization. This will continue to ensure that impacts to listed species and their habitats are minimized. The GElS also suggests that care be exercised in conducting decommissioning activities after an extended SAFSTOR period because there is a greater potential for rare species to colonize the disturbed portion of the site. Prior to the start of and at all times during work activities, workers observe the 25 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report surrounding conditions to maintain a safe environment, which includes the mitigation of a threat to wildlife. Work activities are stopped if unexpected conditions are present. Site environmental specialists support actions to transport or protect the wildlife as necessary.

Based on the above, the planned decommissioning of CR-3 will not result in a direct mortality or otherwise jeopardize the local population of any endangered or threatened species. Therefore, DEF concludes that the impacts of CR-3 decommissioning on endangered or threatened species are bounded by the previously issued GELS.

5.1.8 Radiological The GElS considered radiological doses to workers and members of the public when evaluating the potential consequences of decommissioning activities.

Occupational Dose The occupational radiation exposure to CR-3 plant personnel will be maintained As Low As Reasonably Achievable (ALARA) and below the occupational dose limits in 10 CFR Part 20 during decommissioning. The need for plant personnel to routinely enter radiological areas to conduct maintenance, calibration, inspection, and other activities associated with an operating plant will be reduced, thus it is expected that the occupational dose to plant personnel will significantly decrease after the plant is shutdown and defueled.

DEF has elected to decommission CR-3 using the SAFSTOR alternative. It is expected that the occupational dose required to complete the decommissioning activities at CR-3 will be within the range of SAFSTOR dose estimates (308 - 664 person-rem) provided in Table 4-1 of the GELS.

This is based on the fact that CR-3 is smaller than the reference PWR evaluated in NUREG-0586 and because the ALARA program will be maintained to ensure that occupational dose is maintained ALARA and well within 10 CFR Part 20 limits.

Public Dose The GElS considered doses from liquid and gaseous effluents when evaluating the potential impacts of decommissioning activities on the public. Table G-1 5 of the GElS compared effluent releases between operating facilities and decommissioning facilities and concluded that decommissioning releases are lower. The GElS also concluded that the collective dose and the dose to the maximally exposed individual from decommissioning activities are expected to be well within the regulatory standards in 10 CFR Part 20 and Part 50.

The expected radiation dose to the public from CR-3 decommissioning activities will be maintained within regulatory limits and below comparable levels when the plant was operating through the continued application of radiation protection and contamination controls combined with the reduced source term available in the facility. Also Section 7.1 of the DSEIS concluded that there were no site-specific radiological dose aspects associated with decommissioning of CR-3. Therefore, DEF concludes that the impacts of CR-3 decommissioning on public dose are small and are bounded by the previously issued GELS.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 5.1.9 Radiological Accidents The likelihood of a large offsite radiological release that impacts public health and safety after CR-3 is shut down and defueled is considerably lower than the likelihood of a release from the plant during power operation. This is because the majority of the potential releases associated with power operation are not relevant after the fuel has been removed from the reactor.

NUREG-0586, Supplement 1, assessed the range of possible radiological accidents during decommissioning and separated them into two general categories; fuel related accidents and non-fuel related accidents. Fuel related accidents have the potential to be more severe and zirconium fire accidents, in particular, could produce offsite doses that exceed EPA's protective action guides (Reference 9). As part of its effort to develop generic, risk-informed requirements for decommissioning, the NRC staff performed analysis of the offsite radiological consequences of beyond-design-basis spent fuel pool accidents using fission product inventories at 30 and 90 days and 2, 5, and 10 years. The results of the study indicate that the risk at spent fuel pools is low and well within the Commission's Quantitative Health Objectives. The generic risk is low primarily due to the very low likelihood of a zirconium fire (Reference 4).

Evaluation of spent fuel pool accident risk at CR-3 has indicated that even in the event of a rapid draining of the pool, the risk of a zirconium fire is extremely low (Reference 10). The risk of a zirconium fire at CR-3 was evaluated under both adiabatic and non-adiabatic conditions.

Under non-adiabatic conditions (air cooling), the fuel cladding surface temperature was shown to remain below the clad swell temperature which is well below the onset of rapid oxidation.

Under adiabatic conditions (no heat transfer), the heat-up rate of the hottest fuel assembly provides ample time to take mitigating actions such as restoring makeup or providing spray. As a result, the likelihood that such a scenario would progress to a zirconium fire is not deemed credible.

Furthermore, handling of spent fuel assemblies will continue to be controlled under work procedures designed to minimize the likelihood and consequences of a fuel handling accident.

The radiological dose at the site boundary from a fuel handling accident is estimated to be several orders of magnitude below the EPA protective action guide limit (Reference 10). In addition, emergency plans and procedures will remain in place to protect the health and safety of the public while the possibility of significant radiological releases exists.

The potential for decommissioning activities to result in radiological releases not involving spent fuel (i.e., releases related to decontamination, dismantlement, and waste handling activities) will be minimized by use of procedures designed to minimize the likelihood and consequences of such releases. Additionally, the offsite dose from a bounding radioactive waste handling accident is estimated to be an order of magnitude below the EPA protective action guide limit (Reference 10).

Therefore, DEF concludes that the impacts of CR-3 decommissioning on radiological accidents are small and are bounded by the previously issued GELS.

5.1.10 Occupational Issues Occupational issues are related to human health and safety. The GElS evaluates physical, chemical, ergonomic, and biological hazards. The decommissioning approach outlined in Section 2 poses no unique hazards from what was evaluated in the GElS. DEF will continue to 27 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report maintain appropriate administrative controls and requirements to ensure occupational hazards are minimized and that applicable federal, state and local occupational safety standards and requirements continue to be met. Therefore, DEF concludes that the impacts of CR-3 decommissioning on occupational issues are bounded by the previously issued GEIS.

5.1.11 Cost Decommissioning costs for CR-3 are discussed in Section 4.0 and in Attachment 1 to this report. The GEIS recognizes that an evaluation of decommissioning cost is not a National Environmental Policy Act requirement. Therefore, a bounding analysis is not applicable.

5.1.12 Socioeconomics Decommissioning of CR-3 is expected to result in negative socioeconomic impacts. As CR-3 transitions from an operating plant to a shutdown plant and into the different phases of decommissioning, an overall decrease in plant staff will occur. The lost wages of these plant staff will result in decreases in revenues available to support the local economy and local tax authorities. Some laid-off workers may relocate, thus potentially impacting the local cost of housing and availability of public services.

The GEIS evaluated changes in work force and population, changes in local tax revenues, and changes in public services. The evaluation also examined large plants located in rural areas that permanently shutdown early and selected the SAFSTOR option. The GEIS determined that this situation is the likeliest to have negative impacts. The GEIS concluded that socioeconomic impacts are neither detectable nor destabilizing and that mitigation measures are not warranted.

Therefore, DEF concludes that the impacts of CR-3 decommissioning on socioeconomic impacts are bounded by the previously issued GEIS.

5.1.13 Environmental Justice Executive Order 12898 dated February 16, 1994, directs Federal executive agencies to consider environmental justice under the National Environmental Policy Act. It is designed to ensure that low-income and minority populations do not experience disproportionately high and adverse human health or environmental effects because of Federal actions.

DSEIS Sections 4.9.7.1 and 4.9.7.2 analyzed the census data within 50 miles of CR-3 for minority and low income populations, respectively. The DSEIS analysis concluded that there are minority and low income populations within 50 miles of CR-3. According to the 2000 census data, 14.3% of the population identified themselves as minority individuals and 12.9% of the population were considered low income.

The GEIS reviewed environmental justice decommissioning impacts related to land use, environmental, and human health. DEF does not anticipate any offsite land disturbances during decommissioning, thus the land use impacts are not applicable for CR-3. Based on the radiological environmental monitoring data from CR-3, the DSEIS found no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations (i.e., minority and/or low income populations) in the region as a result of subsistence consumption of water, local food, fish, and wildlife.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report Therefore, DEF concludes that the impacts of CR-3 decommissioning on environmental justice are small and are bounded by the previously issued GELS.

5.1.14 Cultural, Historic, and Archeological Resources Based on a review of the Florida State Historic Preservation Office files, published literature, and information provided by the applicant, the NRC concluded in Section 4.9.6 of the DSEIS that the potential impacts from license renewal of CR-3 on historic and archaeological resources would be small. The NRC's conclusion was based on: 1) the results of archaeological surveys conducted prior to initial plant construction and during subsequent expansion activities, 2) the locations of existing archaeological sites within the CREC, including areas of high potential for additional discoveries, are located away from plant maintenance and operations activities in the protected area, and 3) the environmental protection procedures in use by the CR-3 environmental staff during the environmental site visit.

The cultural, historic, and archeological impact evaluation conducted in the GElS focused on similar attributes as the DSEIS. The GElS evaluated direct effects such as land clearing and indirect effects such as erosion and siltation. The conclusion for the license renewal evaluation is also applicable to the decommissioning period because: 1) decommissioning activities will be primarily contained to disturbed areas located away from areas of existing or high potential for archaeological sites 2) construction activities that disturb greater than one acre of soil need FDEP approval and are required to control sediment and the effects of erosion and 3) environmental protection procedures pertaining to archaeological and cultural resources will remain in effect during decommissioning.

Therefore, DEF concludes that the impacts of CR-3 decommissioning on cultural, historic, and archeological resources are small and are bounded by the previously issued GElS.

5.1.15 Aesthetic Issues The GElS evaluated the aesthetic impacts such as noise and dust during decommissioning as well as changed appearance of the site after decommissioning is complete.

During decommissioning, the impact of activities on aesthetic resources will be temporary and remain consistent with the aesthetics of an industrial plant. In most cases, the GElS concludes that impacts such as dust, construction disarray, and noise would not easily be detectable offsite. This conclusion is applicable to CR-3 because it is located within a 4,738 acre site and BMPs will be used to control potentially adverse impacts.

After the decommissioning process is complete, site restoration activities will result in structures being removed from the site and the site being backfilled, graded and landscaped as needed.

The GElS concludes that the removal of structures is generally considered beneficial to the aesthetic impacts of the site.

Therefore, DEF concludes that the impacts of CR-3 decommissioning on aesthetic issues are bounded by the previously issued GElS.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report 5.1.16 Noise General noise levels during the decommissioning process are not expected to be any more severe than during refueling outages and are not expected to present an audible intrusion on the surrounding community. Some decommissioning activities may result in higher than normal onsite noise levels (i.e., some types of demolition activities). However, these noise levels would be temporary and given the distance to the property boundary, offsite individuals are not expected to experience an audible intrusion.

The GElS indicates that noise impacts are not detectable or destabilizing and makes a generic conclusion that potential noise impacts are small. Based on the standard decommissioning approach proposed for CR-3 and the distance to offsite individuals, DEF concludes that the impacts of CR-3 decommissioning on noise are bounded by the previously issued GELS.

5.1.17 Transportation 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 shipments from the plant would be primarily radioactive wastes and non-radioactive wastes associated with dismantlement and disposal of SSCs.

The estimated cubic feet of radioactive waste associated with CR-3 decommissioning is summarized as follows:

Class A 136,858 cubic feet Class B 876 cubic feet Class C 462 cubic feet GTCC 1,785 cubic feet The GElS estimate for LLRW disposal from a referenced PWR is between 21,000 and 1.5 million cubic feet under the SAFSTOR alternative. DEF estimates the LLRW volume (Class A, B, and C) for CR-3 will be 409,032 cubic feet using the SAFSTOR alternative (including material eligible for additional treatment, processing, volume reduction and recovery, as well as disposal). This volume of LLRW is well within the range analyzed in the GEIS.

DEF must comply with applicable regulations when shipping radioactive waste from decommissioning. The NRC has concluded in the GElS that these regulations are adequate to protect the public against unreasonable risk from the transportation of radioactive materials.

The number of GTCC waste shipments expected to occur during decommissioning are expected to be below the number referenced in the GELS, Table 4-6. These shipments will occur over an extended period of time and will not result in significant changes to local traffic density or patterns, the need for construction of new methods of transportation, or significant dose to workers or the public.

In addition, shipments of non-radioactive wastes from the site are not expected to result in measurable deterioration of affected roads or a destabilizing increase in traffic density.

30 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report Therefore, DEF concludes that the impacts of CR-3 decommissioning on transportation are bounded by the previously issued GElS.

5.1.18 Irreversible and Irretrievable Commitment of Resources Irreversible commitments are commitments of resources that cannot be recovered, and irretrievable commitments of resources are those that are lost for only a period of time.

Uranium is a natural resource that is irretrievably consumed during power operation. After the plant is shutdown, uranium is no longer consumed. The use of the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment, but rather a relatively short-term investment. Since the CR-3 site will be decommissioned to meet the unrestricted release criteria found in 10 CFR 20.1402, the land is not considered an irreversible resource. The only irretrievable resources that would occur during decommissioning would be materials used to decontaminate the facility (e.g., rags, solvents, gases, and tools) and the fuel used for decommissioning activities and transportation of materials to and from the site. However, the use of these resources is minor.

Therefore, DEF concludes that the impacts of CR-3 decommissioning on irreversible and irretrievable commitment of resources are bounded by the previously issued GELS.

5.2 Environmental Impacts of License Termination - NUREG-1496 According to the schedule provided in Section 3 of this report, a license termination plan for CR-3 will not be developed until approximately two years prior to the final site decontamination (approximately the year 2071). At that time, a supplemental environmental report will be submitted as required by 10 CFR 50.82(a)(9). While detailed planning for license termination activities will not be performed until after the SAFSTOR period, the absence of any unique site-specific factors, significant groundwater contamination, unusual demographics, or impediments to achieving unrestricted release suggest that impacts resulting from license termination will be similar to those evaluated in NUREG-1496.

5.3 Discussion of Decommissioning in the DSEIS Postulated impacts associated with decommissioning are discussed in the DSEIS, Section 7.0, which identified six issues related to decommissioning as follows:

Radiation Doses

Waste Management

Air Quality

Water Quality

Ecological Resources

" Socioeconomic Impacts The NRC staff did not identify any new and significant information during their review of the most recent DEF environmental report at that time (Reference 11), the site audit, or the scoping process for license renewal. Therefore, the NRC concluded that there are no impacts related to 31 Revision 0 December 2013

Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report these issues beyond those discussed in the GElS for license renewal or the GElS for decommissioning. For the issues above, the GEISs concluded the impacts are small. The NRC found no site-specific issues related to decommissioning and there are no decommissioning activities contemplated that would alter that conclusion.

5.4 Additional Considerations The CR-3 Permanently Defueled Technical Specifications (Reference 13) requires compliance with applicable procedures recommended in Regulatory Guide 1.33. Therefore, the considerations listed below are obligations and as such, no regulatory commitments are being proposed.

While not quantitative, the following considerations are relevant to concluding that decommissioning activities will not result in significant environmental impacts not previously reviewed:

The release of effluents will continue to be controlled by plant license requirements and plant procedures.

DEF will continue to comply with the Offsite Dose Calculation Manual, Radiological Environmental Monitoring Program, and the Groundwater Protection Initiative Program during decommissioning.

Releases of non-radiological effluents will continue to be controlled per the requirements of the NPDES permit and applicable State of Florida permits.

Radiation protection principles used during plant operations will remain in effect during decommissioning.

Transport of radioactive waste will be in accordance with plant procedures, applicable Federal regulations, and the requirements of the receiving facility.

" Site access control during decommissioning will minimize or eliminate radiation release pathways to the public.

Additionally, draft NUREG-2157 (Reference 12) found that the generic environmental impacts of ongoing spent fuel storage are small.

5.5 Conclusions Based on the above discussions, DEF concludes that the environmental impacts associated with planned CR-3 site-specific decommissioning activities will be bounded by appropriate, previously issued environmental impact statements. Specifically, the environmental impacts are bounded by the GElS (Reference 4).

1. The postulated impacts associated with the decommissioning method chosen, SAFSTOR, have already been considered in the most recent DSEIS and GELS.

2. There are no unique aspects of CR-3 or of the decommissioning techniques to be utilized that would invalidate the conclusions reached in the most recent DSEIS and GELS.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report

3. The methods assumed to be employed to dismantle and decontaminate CR-3 are standard construction-based techniques fully considered in the most recent DSEIS and GELS.

Therefore, it can be concluded that the environmental impacts associated with the site-specific decommissioning activities for CR-3 will be bounded by appropriate previously issued environmental impact statements.

10 CFR 50.82(a)(6)(ii) states that licensees shall not perform any decommissioning activities, as defined in 10 CFR 50.2, that result in significant environmental impacts not previously reviewed.

No such impacts have been identified.

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Crystal River Unit 3 Post-Shutdown Decommissioning Activities Report

6.0 REFERENCES

1. Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report," Revision 1, dated June 2013.

2. Letter from J.A. Franke, Vice President, Crystal River Nuclear Plant, "Crystal River Unit 3 -

Certification of Permanent Cessation of Power Operations and that Fuel Has Been Permanently Removed from the Reactor," dated February 20, 2013. (ADAMS Accession No. ML13056A005)

3. Letter from C. Gratton, Senior Project Manager, Office of Nuclear Reactor Regulation, U.S.

Nuclear Regulatory Commission, to J.A. Franke, Vice President, Crystal River Nuclear Plant, "Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel From the Reactor," dated March 13, 2013.

(ADAMS Accession No. ML13058A380)

4. NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors," Final Report dated November 2002.

5. AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," dated May 1986.

6. Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," Revision 2, dated October 2011.

7. NUREG-1496, "Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities," dated July 1997.

8. NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 44, Regarding Crystal River Unit 3 Nuclear Generating Plant, Draft Report for Comment," dated May 2011.

9. PAG Manual, "Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment," dated March 2013.

10. CR-3 to NRC letter, "Crystal River Unit 3- License Amendment Request #315, Revision 0, Permanently Defueled Emergency Plan and Emergency Action Level Scheme, and Request for Exemption to Certain Radiological Emergency Response Plan Requirements Defined by 10 CFR 50," dated September 26, 2013. (ADAMS Accession No. ML13274A584)

11. Progress Energy - Crystal River Unit 3 License Renewal Application, "Applicant's Environmental Report - Operating License Renewal Stage, Crystal River Unit 3," dated November 2008. (ADAMS Accession No. ML090080731)

12. NUREG-2157, "Waste Confidence Generic Environmental Impact Statement, Draft Report for Comment," dated September 2013.

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13. CR-3 to NRC letter, "Crystal River Unit 3 - License Amendment Request #316, Revision 0, Revise and Remove License Conditions and Revision to Improved Technical Specifications to Establish Permanently Defueled Technical Specifications," dated October 29, 2013.

(ADAMS Accession No. ML13316C083)

14. FPSC, Docket No. 130207-El / Order No. PSC-1 3-0452-FOF-El, In re: Petition for declaratorystatement with respect to use of decommissioning trust fund dollars for spent fuel and other non-radiologicaldecommissioning costs for Crystal River 3 Nuclear Plant.

(Issued October 9, 2013) 35 Revision 0 December 2013

v t e Letter Sequence Request
TAC:MF3210, (Open)
Initiation Request, Request, Request, Request, Request Acceptance... Administration Meeting Questions 28 April 2014 14 May 2014 Answers 17 June 2014 Results Approval... Other: ML14034A023, ML14321A751
MONTHYEAR2014-04-28 [Table View]

3F1213-02, Post-Shutdown Decommissioning Activities Report

Text

Subject:

Reference:

Dear Sir:

Enclosure:

1.0 INTRODUCTION

SUMMARY

2.0 DESCRIPTION

6.0 REFERENCES

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