ML23313A132

Request for Additional Information for the Environmental Assessment of the License Termination Plan for Crystal River Unit 3 Nuclear Generating Plant

ML23313A132
Person / Time
Site:	Crystal River
Issue date:	11/15/2023
From:	Caverly J NRC/NMSS/DREFS/ERMB
To:	Reid B ADP CR3
References
Download: ML23313A132 (7)

Text

November 15, 2023 Billy Reid, Site Executive ADP CR3, LLC 157060 West Power Line Street Crystal River, FL 34428

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE ENVIRONMENTAL ASSESSMENT OF THE LICENSE TERMINATION PLAN FOR CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT (DOCKET NUMBER:

05000302)

Dear Billy Reid:

By letter dated December 12, 2022 (Agencywide Documents Access and Management System (ADAMS) ML22355A441), as supplemented by letter dated June 9, 2023 (ML23163A063),

Accelerated Decommissioning Partners Crystal River Unit 3, LLC (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) to approve a request to add a condition to include License Termination Plan requirements to the NRC license, No. DPR-72, for Crystal River Unit 3 Nuclear Generating Plant. On July 25, 2023, the NRC accepted the application for detailed technical review (ML23187A111).

The NRC staff has identified areas where additional information is needed to complete its environmental assessment for the proposed license termination plan decommissioning activities. Please see the enclosed request for additional information and provide a response within 60 days of receiving this letter. We can also schedule a clarifying call if this would be of help to you in responding to this request.

In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

B. Reid 2 If you have any questions concerning this letter, please contact Marla Morales via email at marla.morales@nrc.gov, or via phone at 301-415-0715.

Sincerely, Signed by Caverly, Jill on 11/15/23 Jill S. Caverly, Acting Chief Environmental Review Materials Branch Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket No. 05000302

Enclosure:

As Stated

ML23313A132 OFFICE PM REFS LA REFS BC REFS NAME MMorales AWalker-Smith JCaverly DATE 11/13/2023 11/13/2023 11/15/2023 Crystal River Unit 3 Request for Additional Information for Environmental Assessment The purpose of this request for additional information (RAI) is to obtain additional information and data that is necessary for the U.S. Nuclear Regulatory Commission (NRC) to fulfill its responsibilities under the National Environmental Policy Act of 1969, as amended. The NRC staff will prepare an environmental assessment (EA) pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 51.21 and 51.30. The staff will use the guidance in NUREG-1748 (Environmental Review Guidance for Licensing Actions Associated with Nuclear Material Safety and Safeguards Programs), especially Chapter 3, to prepare the EA. To support its environmental reviews, the NRCs regulations in 10 CFR 51.45, Environmental Reports General Requirements, and 51.60, Environmental ReportsMaterials Licenses, address the need for a licensee or applicant to submit an environmental report. Chapter 6 of NUREG-1748 provides guidance regarding the contents of an environmental report.

After reviewing the Accelerated Decommissioning Partners (ADP) Crystal River Unit 3 Nuclear Generating Plant (CR3) license termination plan (Agencywide Documents Access and Management System ML23160A296), the NRC staff has determined that the following additional information is needed for the staff to complete an EA assessing the potential impacts of the decommissioning activities. The requested information is consistent with the requirements for an environmental report as detailed in chapter 6 of NUREG-1748.

Permitting (PR) RAI PR-1: Provide a list of the various Federal, State, and local agency licenses and permits issued to ADP related to the decommissioning activities associated with the License Termination Plan (LTP).

Land Use (LU) RAI LU-1: Are there plans to revegetate or recontour the land surface for areas disturbed by decommissioning activities?

Transportation (TR) RAI TR-1: LTP section 8.5.2.15 states, The transportation impacts of decommissioning are dependent on the number of shipments to and from the plant, the types of shipments, the distance the material is shipped, and the radiological waste quantities and disposal plans. The section further states that most waste will be shipped by rail for both radiological and non-radiological waste. Provide an estimate of the number of rail shipments, and truck shipments, if applicable.

Water Resource (WR) RAI WR-1: LTP section 8.5.2.3 states that, during the planning and dormancy periods, stormwater runoff and drainage paths will be maintained in their current configuration. Will drainage paths be altered during active decommissioning activities? If so, discuss how they will potentially be altered and if there could be onsite or offsite impacts to land use or cultural sites.

Enclosure

Terrestrial Ecology (TE) RAI TES-1: Provide copies of any correspondence with the U.S. Fish and Wildlife Service or National Oceanic and Atmospheric Administration Fisheries since shutdown of the plant.

Aquatic Ecology (AE) RAIs AE-1: What are the applicants plans for receiving permits from US Army Corps of Engineers and the State of Florida for ground disturbance to remove shoreline structures?

AE-2: Provide overview (general) information on water intake and discharges from Duke Units 4 and 5.

AE-2: Provide copy of any permits from US Army Corps of Engineers for dredging for Duke Units 4 and 5.

Socioeconomics (SOC) RAIs SOC-1: LTP section 8.5.2.10 states that there has been a decrease in the number of jobs due to decommissioning. Please provide an estimate of the number of workers that are currently employed or will be employed during the various phases of decommissioning, and for comparison purposes the number of workers during operations.

SOC-2: Please provide a description of where the workers reside during employment (i.e., are the workers commuting from nearby towns or local to the area where the plant resides).

Environmental Justice (EJ) RAI EJ-1: Text in LTP section 8.5.2.11 concludes that the environmental justice impacts are SMALL and bounded by the Generic Environmental Impact Statement (GEIS) [NUREG-0586 Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities]. However, the GEIS specifically states that environmental justice requires a site-specific analysis and does not generically resolve potential impacts. Therefore, environmental justice should be analyzed on a site-specific basis and is thus not bounded by the GEIS. Please provide a site-specific environmental justice analysis and a basis for concluding SMALL impacts.

Waste Management (WM) RAIs WM-1: Provide the name of the municipal solid waste or construction and demolition waste landfill that will be used. Also, provide an estimated volume of the solid non-hazardous waste that will be disposed of at a municipal solid waste or construction and demolition waste landfill.

WM-2: Provide staff with a copy of the waste management plan mentioned in LTP section 8.5.1.3.

WM-3: Provide the estimated volumes of low-level radioactive waste by Class type and the intended disposal facility or provide direction to where this information can be found.

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Historic and Cultural (HC) RAIs HC-1: LTP section 8.5.2.12 states that [the] license renewal evaluation is also applicable to the decommissioning period. It is unclear on how the predicted effects from license renewal (i.e., maintain status quo of activities) and the predicted effects from decommissioning activities (e.g., deconstruction, removal of sub/surface infrastructure, soil removal) are similar given the proposed activities. With respect to the presence/absence of cultural resources in the area of potential effect (APE), please provide the rationale for why the evaluation of cultural resources would be applicable given the different type of activities for the various phases.

HC-2: Please provide any documentation of coordination with the Florida State Historic Preservation Office (SHPO) and/or Tribes regarding planned LTP decommissioning activities.

HC-3: Please provide a copy of the Miller (1973) reference cited in the historic and cultural analysis and any other supporting cultural resources survey reports used to evaluate the site.

HC-4: Facility construction was authorized in 1968 and completed in 1976 - therefore, the completed facility will be 50 years of age in 2026. Given the age of the facility and to assist staff in assessing the potential presence of historic properties, per 36 CFR 800.4 "Identification of Historic Properties," provide an evaluation of the historic nature of the facility to determine its National Register of Historic Places-eligibility. Please submit the evaluation report and any associated correspondence with Florida SHPO.

HC-5: Please provide a map of the APE with respect to decommissioning activities for CR3, including any lay down areas or land used for temporary storage of materials associated with decommissioning so that staff can evaluate potential impacts to cultural resources. In addition, please provide thorough documentation of previously recorded cultural resources in the Crystal River Energy Complex (CREC) operating area and adjacent parcels so that direct and indirect effects upon cultural resources may be adequately evaluated and addressed.

HC-6: Please provide a copy of corporate procedure EVC SUBS 00105 - Archaeological and Cultural Resources.

HC-7: Was a cultural resources management plan prepared pursuant to the draft supplemental environmental impact statement (SEIS) (NUREG-1437, Supplement 44)? Please provide a discussion of why or why not. If a cultural resources management plan was prepared, please provide a copy.

HC-8: Has CREC been subject to modern cultural resources survey? If not, please provide a discussion as to why a modern cultural resources survey is not warranted.

Air Quality (AQ) RAIs AQ-1: The LTP states that the site contains two coal fossil-fueled units. The draft SEIS (NUREG-1437, Supplement 44) states that CREC had four coal-fired units (CR-1, CR-2, CR-4, and CR-5) and that units CR-1 and CR-2 were planned for shutdown in 2020. Verify that these two units are shutdown. Are the remaining two units (CR-4 and CR-5) currently operating and is operation planned to continue after decommissioning of CREC?

AQ-2: What is the status of the Title V Permit for CREC? The LTP states that the emergency diesel generators were recently exempted from the Title V and that a Notice of Intent was filed.

Does the permit cover other sources of emissions from CR-3?

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AQ-3: Describe how often coal deliveries to the CREC site occur and the delivery method (e.g.,

barge, truck, rail).

AQ-4: The LTP states that [o]utside the licensed footprint are 2 gas combined cycle units.

What distance are these 2 units located from CREC? When did these units begin operating?

AQ-5: Provide the workforce at the time CR-3 ceased operation, an estimate of the number of workers onsite during decommissioning and where the workers would likely be commuting from (e.g., surrounding counties). Will the workforce decrease as decommissioning progresses? A response to this RAI could be incorporated into the SOC-1 response.

Cumulative Impacts (CI) RAI CI-1: Provide a discussion on present and reasonably foreseeable future actions in the area that could have impacts overlapping in time or place with the impacts from this proposed action. For example, are there currently operating or planned construction of commercial or industrial facilities that could have overlapping effects on traffic, groundwater resources, or other resources?

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