ML24081A068

LTP Environmental Assessment

ML24081A068
Person / Time
Site:	Crystal River
Issue date:	07/31/2024
From:	Minor A NRC/NMSS/DREFS/ERMB
To:
References
NRC-2024-0124
Download: ML24081A068 (90)

Text

Office of Nuclear Material Safety & Safeguards ML24081A068 Environmental Assessment for the License Termination Plan for Crystal River, Unit 3 in Citrus County, Florida Completed: July 2024 Environmental Center of Expertise Division of Rulemaking, Environmental, and Financial Support

ML24081A068 Environmental Assessment for the License Termination Plan for Crystal River, Unit 3 in Citrus County, Florida Completed: July 2024 Office of Nuclear Material Safety & Safeguards

i Table of Contents LIST OF FIGURES......................................................................................................... iii LIST OF TABLES.......................................................................................................... iv ABBREVIATIONS AND ACRONYMS............................................................................ v 1

INTRODUCTION................................................................................................. 1-1 1.1 Proposed Action.................................................................................................... 1-3 1.2 Purpose of and Need for the Proposed Action...................................................... 1-3 1.3 Alternative to the Proposed Action........................................................................ 1-4 1.4 Scope of the Environmental Analysis.................................................................... 1-4 2

PROPOSED ACTION AND ALTERNATIVES.................................................... 2-1 2.1 Proposed Action.................................................................................................... 2-1 2.1.1 History of the CR3 Facility and License.................................................. 2-1 2.1.2 Decommissioning Activities.................................................................... 2-3 2.2 Alternatives........................................................................................................... 2-5 3

AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS.................... 3-1 3.1 Land Use............................................................................................................... 3-2 3.1.1 Land Use Including Site Description and Vicinity................................... 3-2 3.1.2 Land-Use Direct and Indirect Impacts.................................................... 3-3 3.2 Visual and Scenic Resources/Aesthetics............................................................. 3-3 3.2.1 Description of the Visual and Scenic Affected Environment.................. 3-3 3.2.2 Visual and Scenic Resources Direct and Indirect Impacts.................... 3-4 3.3 Climatology, Meteorology, and Air Quality............................................................ 3-4 3.3.1 Description of Site Climatology and Meteorology................................... 3-4 3.3.2 Description of Site Air Quality................................................................. 3-5 3.3.3 Greenhouse Gases and Climate Change.............................................. 3-5 3.3.4 Direct and Indirect Impacts on Air Quality.............................................. 3-7 3.4 Noise..................................................................................................................... 3-8 3.4.1 Description of Noise Levels................................................................... 3-8 3.4.2 Noise Direct and Indirect Impacts.......................................................... 3-8 3.5 Geology and Soils................................................................................................. 3-8 3.5.1 Regional and Site-Specific Geology....................................................... 3-8 3.5.2 Regional, Site-Specific Geology and Soils Direct and Indirect Impacts................................................................................................... 3-9 3.6 Water Resource.................................................................................................... 3-9 3.6.1 Description of Affected Environment for Surface Water......................... 3-9 3.6.2 Direct and Indirect Impacts on Surface Water...................................... 3-11

ii 3.6.3 Description of Affected Environment for Groundwater......................... 3-12 3.6.4 Direct and Indirect Impacts on Groundwater........................................ 3-14 3.7 Historic and Cultural Resources.......................................................................... 3-14 3.7.1 Historic and Cultural Resources Affected Environment........................ 3-14 3.7.2 Historic and Cultural Resources Direct and Indirect Impacts............... 3-16 3.8 Ecological Resources.......................................................................................... 3-17 3.8.1 Description of Terrestrial Resources.................................................... 3-17 3.8.2 Direct and Indirect Impacts on Terrestrial Resources.......................... 3-23 3.8.3 Description of Aquatic Resources........................................................ 3-24 3.8.4 Direct and Indirect Impacts to Aquatic Resources................................ 3-28 3.8.5 Federally Protected Ecological Resources........................................... 3-29 3.9 Socioeconomics.................................................................................................. 3-40 3.9.1 Socioeconomic Characteristics of the Site Vicinity............................... 3-40 3.9.2 Socioeconomic Direct and Indirect Impacts......................................... 3-41 3.10 Public and Occupational Health.......................................................................... 3-42 3.10.1 Existing Radiological Conditions.......................................................... 3-42 3.10.2 Public and Occupational Dose Health and Safety Direct and Indirect Impacts................................................................................................. 3-43 3.11 Transportation and Traffic................................................................................... 3-45 3.11.1 Transportation Affected Environment................................................... 3-45 3.11.2 Transportation Direct and Indirect Impacts........................................... 3-46 3.12 Environmental Justice......................................................................................... 3-47 3.12.1 Minority Populations in the Vicinity of the CR3 Site.............................. 3-47 3.12.2 Low-income Populations in the Vicinity of the CR3 Site....................... 3-48 3.12.3 Direct and Indirect Impacts................................................................... 3-48 3.13 Waste Management........................................................................................... 3-49 3.13.1 Radioactive Waste............................................................................... 3-49 3.13.2 Nonradioactive Waste.......................................................................... 3-51 3.13.3 Waste Management Direct and Indirect Impacts................................. 3-51 3.14 Cumulative Impacts............................................................................................. 3-53 3.15 Summary of Environmental Consequences........................................................ 3-54 4

CONSULTATION AND COORDINATION.......................................................... 4-1 4.1 State Review......................................................................................................... 4-1 4.2 National Historic Preservation Act Section 106 Consultation................................ 4-1 4.3 Endangered Species Act Section 7 Consultation.................................................. 4-1 5

CONCLUSIONS AND RECOMMENDATIONS................................................... 5-1 6

LIST OF PREPARERS........................................................................................ 6-1 7

REFERENCES.................................................................................................... 7-1

iii LIST OF FIGURES Figure 1-1 General Timeline of Decommissioning Activities (Source: NRC 2002a)............ 1-2 Figure 2-1 CR3 Site Map. The area outlined in yellow represents the 358-ha (884-ac)

NRC-Licensed Area (Source: ADP 2024a)........................................................ 2-2 Figure 2-2 CR3 Layout Map. The areas outlined in red represent the 11-ha (27-ac)

Proposed Action Area (Source: ADP 2024b)..................................................... 2-3 Figure 3-1 Crystal River Unit 3 Storm Drain Locations (Source: ADP 2024a)................... 3-11 Figure 3-2 Crystal River Unit 3 Groundwater Monitor Well Locations. Deep Wells also are installed at locations 1, 3, and 6 (Source: ADP 2024a).............................. 3-13 Figure 3-3 Location of W. Power Line Street and US 19 (Source: EPA 2024).................. 3-46

iv LIST OF TABLES Table 3-1 Environmental Resource Areas Bounded by the Decommissioning GEIS......... 3-1 Table 3-2 Federally and State-Listed Terrestrial Species that May Occur Within or Near the CR3................................................................................................... 3-19 Table 3-3 Avian Species Protected Under the MBTA Near the CR3................................ 3-22 Table 3-4 Federally and State-Listed Aquatic Species that May Occur Within or Near the CR3............................................................................................................ 3-26 Table 3-5 NRC Effect Determinations for ESA-Protected Species and Habitats from the CR3 Decommissioning and License Termination Activities Under FWS and NMFS Jurisdiction..................................................................................... 3-31 Table 3-6 EFH Protected Under the MSA Near the CR3................................................. 3-38 Table 3-7 CR3 Cumulative Site Exposure........................................................................ 3-44 Table 3-8 Projected LLRW Disposal Volumes................................................................. 3-50 Table 3-9 Summary of LLRW Disposal Facilities and Capacities.................................... 3-52 Table 3-10 Summary of Environmental Consequences Specifically Identified in the Decommissioning GEIS................................................................................... 3-54 Table 6-1 List of Prepares.................................................................................................. 6-1

v ABBREVIATIONS AND ACRONYMS

°C degrees Celsius

°F degrees Fahrenheit ACHP Advisory Council on Historic Preservation APE area of potential effect AQCR Air Quality Control Region ADP Accelerated Decommissioning Partners Crystal River 3, LLC ac acre(s)

ALARA as low as is reasonably achievable BMP best management practices CCCS Citrus Combined Cycle Station cm centimeter(s)

CFR Code of Federal Regulations CR3 Crystal River Unit 3 Nuclear Power Station CREC Crystal River Energy Complex CO2e carbon dioxide equivalent DCGL Derived Concentration Guidelines Levels DEF Duke Energy of Florida DPS distinct population segment EA environmental assessment EPA U.S. Environmental Protection Agency EFH essential fish habitat ESA Endangered Species Act of 1973 FDEP Florida Department of Environmental Protection ft foot (feet)

FSS final site survey FWS U.S. Fish and Wildlife Service GCRP U.S. Global Change Research Program GEIS Generic Environmental Impact Statement g

gram GTCC Greater-than-Class-C (waste) ha hectare(s) in inch(es)

ISFSI Independent Spent Fuel Storage Installation IPaC Information for Planning and Consultation km kilometer(s)

L liter(s)

LLRW low-level radioactive waste LTP License Termination Plan m

meter(s)

vi mi mile(s)

MBTA Migratory Bird Treaty Act of 1918 MMPA Marine Mammal Protection Act of 1972 mrem millirem MSA Magnuson-Stevens Fishery Conservation and Management Act mSv millisievert MT metric tons MWe megawatt electric MWt megawatt thermal NEPA National Environmental Policy Act of 1969 NHPA National Historic Preservation Act of 1966, as amended NMFS National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration NRHP National Register of Historic Places NLAA not likely to adversely affect NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission OTSG once-through steam generator pCi picocurie(s) ppm parts per million PSDAR Post-Shutdown Decommissioning Activities Report PWR pressurized-water reactor RPP Radiation Protection Program SEIS supplemental environmental impact statment SHPO State Historic Preservation Office Siemens S

TEDE Total Effective Dose Equivalent WCS Waste Control Specialists yr year(s)

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INTRODUCTION By letter dated December 12, 2022, Accelerated Decommissioning Partners Crystal River Unit 3, LLC (ADP, licensee) submitted an application to the U.S. Nuclear Regulatory Commission (NRC or Commission) requesting a license amendment to license number DPR-72 (Docket Number 50-302) to approve the License Termination Plan (LTP) for the Crystal River Unit 3 Nuclear Power Station (CR3), located in Citrus County, Florida (ADP 2022) and the NRC accepted the application for review by a letter dated July 25, 2023 (NRC 2023a). ADP submitted an updated LTP in March 2024 (ADP 2024a).

The CR3 is part of the larger Crystal River Energy Complex (CREC), which is located on the Gulf of Mexico. Duke Energy of Florida (DEF) is the owner of the complex, with ADP assuming control of the CR3. During activities to replace steam generators, a portion of the containment concrete wall became delaminated, and while completing repairs, additional delamination occurred. The CR3 was a commercial nuclear power plant that is licensed by the NRC, but it stopped operations in 2009 and was officially retired on February 5, 2013 (ADP 2024a).

If ADPs request is granted, a condition would be added to its license reflecting the NRCs approval of its LTP and establishing criteria for determining when changes to the LTP require prior NRC approval (ADP 2024a).

Submittal of the LTP is one of the final steps in the NRCs nuclear power reactor decommissioning process, which involves the safe removal of a facility from service and the reduction of residual radioactivity to a level that permits NRC license termination. Figure 1-1 provides a general timeline for the overall decommissioning process. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.82, Termination of license, provides the requirements for terminating power reactor licenses. Those requirements specify what must be included in a licensees LTP when submitted to the NRC for review and approval. The LTP describes the process the licensee will use to meet the requirements for terminating the license and releasing the site for unrestricted use.

The NRC will terminate the license if it determines that (1) the site meets performance-based criteria for unrestricted site release, in accordance with 10 CFR 20.1402, Radiological criteria for unrestricted use, and (2) the facility has been dismantled in accordance with the approved LTP. The portion of the site associated with the independent spent fuel storage installation (ISFSI) will remain under the NRCs regulatory jurisdiction. Although the terminology license termination is used throughout this environmental assessment (EA), the 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, license will continue in effect for the ISFSI only. The CR3 license will be considered terminated in all other aspects and will only apply to the site occupied by the ISFSI. For simplicity, this EA will refer to terminating the license. When it does so, it means releasing the entire siteexcept for the ISFSIfor unrestricted use. The ISFSI will remain under the 10 CFR Part 50 license until such time as the spent fuel is moved.

The NRC staff has prepared this EA to evaluate and document the potential environmental impacts resulting from the NRCs approval of ADPs license amendment request and subsequent implementation of the LTP. The staff also is performing a detailed safety analysis of ADPs license amendment request. The results of the safety analysis will be documented in a separate Safety Evaluation Report. The NRC decision whether to approve the license amendment request will be based on the results of the NRC staffs reviews documented in this EA and the Safety Evaluation Report.

1-2 Figure 1-1 General Timeline of Decommissioning Activities (Source: NRC 2002a)

1-3 1.1 Proposed Action The proposed action is the review and subsequent approval, if appropriate, of the CR3 LTP.

In its license amendment request, ADP requested an amendment to the CR3 license to add license conditions that (1) reflect the NRC staffs approval of the LTP and (2) provide criteria for when NRC approval is needed for subsequent LTP changes. If the NRC approves the LTP, approval will be issued in the form of an amendment to the CR3 license that adds the requested license conditions.

1.2 Purpose of and Need for the Proposed Action The purpose of and need for the proposed action is to allow completion of decommissioning of the CR3 site by ADP, termination of the CR3 operating license by the NRC, and subsequent release of the site for unrestricted use. The NRC regulation at 10 CFR 50.82 sets forth the process for the licensee to decommission its nuclear power plant, including submission of the LTP. The NRC will approve the LTP, provided that the LTP meets the criteria in 10 CFR 50.82(a)(10).

The NRC staffs review and approval of the LTP is the regulatory mechanism by which the NRC ensures that final decommissioning activities are appropriately completed. As part of the LTP review process, the NRC staff determines whether the procedures and activities planned for completing decommissioning (e.g., adequacy of radiation release criteria and adequacy of the design of the final radiation survey) appear sufficient as described in the LTP.

ADP intends to meet the criteria for unrestricted use. The NRCs performance-based radiological criteria for unrestricted release of a licensed site, as specified by 10 CFR 20.1402, is:

A site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a TEDE[1] to an average member of the critical group that does not exceed 25 millirem (mrem) (0.25 milliSievert [mSv]) per year, including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA). Determination of the levels which are ALARA must take into account consideration of any detriments, such as deaths from transportation accidents, expected to potentially result from decontamination and waste disposal.

ADP has proposed derived concentration guideline levels to meet the 10 CFR 20.1402 criteria.

The NRC staff must determine whether additional planning, investigation, or other activities by ADP are necessary to support the NRCs decision on approving the LTP. Once decommissioning has been completed, the NRC licenses have been terminated except for the ISFSI site, and the site has been released for unrestricted use, ADP can make the CR3 site available for another use.

1 Total Effective Dose Equivalent (TEDE) means the sum of the effective dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures). Dose equivalent means the product of the absorbed dose in tissue, quality factor, and all other necessary modifying factors at the location of interest. The units of dose equivalent are the rem and Sievert (Sv). (10 CFR 20.1003)

1-4 1.3 Alternative to the Proposed Action As an alternative to the proposed action, the NRC staff considered the no-action alternative, under which the NRC would not approve the LTP or the license amendment request because regulatory requirements have not been met. Consequently, the CR3 license would not be terminated, decommissioning and other onsite maintenance and operations activities involving the storage of spent nuclear fuel would continue, and the CR3 site would not be released for unrestricted use. The NRC regulation at 10 CFR 50.82(a)(10) states that the Commission shall approve an LTP, by license amendment, if the LTP demonstrates that the remainder of the decommissioning activities will be performed in accordance with the NRCs regulations, will not be inimical to the common defense and security or to the health and safety of the public, and will not have a significant effect on the quality of the environment.

If the NRC was unable to approve the LTP because the regulatory requirements were not met, then ADP would have to take the necessary actions to ensure the regulations are met. ADP would need to take additional action to prepare an LTP that meets the requirements in 10 CFR 50.82(a)(10). The updated LTP would then need to be submitted to NRC for approval prior to license termination. Under this scenario, until ADP resubmits the LTP, activities at the CR3 would likely continue and the environmental impacts would neither increase nor decrease because of the additional time required for the LTP resubmission.

1.4 Scope of the Environmental Analysis To fulfill its obligations under the National Environmental Policy Act (NEPA) of 1969, the NRC must evaluate the radiological and non-radiological environmental impacts associated with approval of the LTP and subsequent termination of the license. These evaluations involve an assessment of the impacts of remaining decommissioning and site restoration activities documented in the LTP and license termination activities (e.g., final site survey).

The NRC previously evaluated the potential environmental impacts of nuclear reactor decommissioning in NUREG-0586, Supplement 1, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (GEIS) (NRC 2002a). The Decommissioning GEIS is used by NRC staff to evaluate environmental impacts that would occur during the decommissioning of nuclear power reactors. It is considered "generic" in that it evaluates environmental impacts from decommissioning activities common to nuclear power reactor facilities. The Decommissioning GEIS addresses decommissioning of nuclear power reactors licensed by the NRC, including pressurized-water reactors (PWRs), boiling-water reactors, and multiple reactor stations. The generic analysis was based, in part, on experience with reactors that had already undergone or were undergoing decommissioning.

The CR3 was not evaluated in the Decommissioning GEIS; however, the GEIS did evaluate the Maine Yankee Nuclear Power Plant. The Maine Yankee Nuclear Power Plant was a 2,700 megawatt thermal (MWt) PWR designed by Combustion Engineering. Similarly, the CR3a typical single-unit PWR supplied by Babcock & Wilcoxwas initially licensed to operate at a maximum thermal power level of 2,452 MWt. Both plants are similarly designed PWRs that have two steam generators, four reactor coolant pumps, and a pressurizer. The main difference between the designs is that the Combustion Engineering design has recirculating steam generators, and the Babcock & Wilcox design has once-through steam generators, though, this difference does not mean that the GEIS would not bound CR3. In 1981, 2002, and 2007, the NRC approved three DEF requests to increase the licensed core power level to a maximum thermal power level of 2,609 MWt (ADP 2024a). In addition, the site area for Maine Yankee

1-5 Nuclear Power Plant was estimated as 332 hectares (ha) (820 acres [ac]), whereas the site area for the CR3 is smaller [11 ha (27 ac)]. Because the power level of Maine Yankee was higher than that of the CR3, Maine Yankee was an overall larger facility, meaning it had a larger footprint, required a larger volume of water intake, and generally had greater environmental effects. Therefore, the environmental impacts of decommissioning Maine Yankee Nuclear Power Plant evaluated in the GEIS would bound the environmental impacts of decommissioning of the CR3 because of the lower power level, smaller footprint, and lower water intake. Thus, the GEIS is applicable to the decommissioning of the CR3.

The scope of the Decommissioning GEIS is based on decommissioning activities undertaken from the time a licensee certifies it has permanently ceased power operations until the operating license is terminated. The NRC staff concluded in the GEIS that the environmental impacts of decommissioning, including license termination activities, can be determined generically for all nuclear power plants and will have SMALL impacts2 in all but six environmental resource areas.

The GEIS concluded that two of these six resource areas (i.e., (1) threatened and endangered species and (2) environmental justice) must always be evaluated on a site-specific basis in site specific EAs, such as this EA for the CR3 LTP. Depending on site-specific circumstances, the following four additional resource areas are considered to be conditionally site specific:

(1) offsite land use, (2) historic and cultural resources, (3) terrestrial ecology beyond the operational area, and (4) aquatic ecology beyond the operational area (NRC 2002a).

The Decommissioning GEIS did not address the affected environment; cumulative impacts; climate change and greenhouse gases (GHGs); and nonradioactive waste management from decommissioning activities. Therefore, this EA also provides a description of the affected environment at the CR3, considers cumulative impacts, and evaluates the impacts of climate change and GHGs, as well as nonradioactive waste management.

In the Decommissioning GEIS, the staff determined that a decommissioning cost assessment is not a NEPA requirement but still included a decommissioning cost evaluation (without environmental significance levels) because accurate decommissioning cost estimates are necessary for safe and timely plant decommissioning. Licensees must submit decommissioning funding plans annually. Upon receipt of a decommissioning funding plan, the NRC reviews the estimates to determine if the licensee has demonstrated compliance with 10 CFR 50.82(a)(8)(v)-(vii), thus providing assurance that the licensee is maintaining the sufficient funds for decommissioning.

2 The NRC staff use a standard of significance in the GEIS, described as either SMALL, MODERATE, or LARGE. SMALL impacts are defined as environmental impacts that are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource (NRC 2002a).

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PROPOSED ACTION AND ALTERNATIVES 2.1 Proposed Action This section discusses the history of the site and the decommissioning activities to be performed in accordance with the LTP.

2.1.1 History of the CR3 Facility and License The CR3 is part of the CREC, which is approximately 12 kilometers (km) (7.5 miles [mi])

northwest of the City of Crystal River, and 112 km (70 mi) north of Tampa. The CREC occupies 1,917 hectares (ha) (4,738 acres [ac]) of land, of which 429.8 ha (1,062 ac) is developed.

Structures within the 358-ha (884-ac) NRC-licensed boundary include the CR3, two coal-fueled power generation units, two large cooling towers, parking lots, coal delivery and storage areas, ash storage area, office buildings, warehouses, barge handling docks, and a railroad (ADP 2024a) (figure 2-1). The CR3 site occupies approximately 11 ha (27 ac) within the NRC-licensed boundary (ADP 2024a) (figure 2-2). Located outside the NRC-licensed boundary are two gas combined-cycle units.

Major milestones related to the construction and operational history of CR3 are listed below (ADP 2019):

• Construction Permit Issued: September 25, 1968

• Operating License Issued: January 28, 1977

• Commercial Operation Began: March 13, 1977

• Final Reactor Shutdown: September 26, 2009

• Final Removal of Fuel from Reactor Vessel: May 28, 2011

• Initial Operating License Expiration: December 3, 2016

• Final Transfer of Fuel from Pool to ISFSI Pad January 12, 2018 On December 2, 2013, DEF submitted a Post-Shutdown Decommissioning Activities Report (PSDAR) to NRC selecting SAFSTOR as the plant decommissioning strategy (Duke 2013). On January 22, 2019, DEF submitted a Partial Site Release request to the NRC to reduce the licensed footprint by releasing 1,560 ha (3,854 ac) of the non-impacted areas from the 1,917 ha (4,738 ac) CREC (Duke 2019a). By letter dated January 2, 2020, the NRC approved the release of the non-impacted areas (NRC 2020a). The remaining 358-ha (884-ac) NRC-licensed area, also referred to as the controlled area, is defined by the new site boundary depicted in figure 2-1. ADP plans to request partial site releases and planned partial license terminations in phases.

By letter dated June 14, 2019, and supplemented by letters dated January 17, 2020, and March 5, 2020 (Duke 2019b, 2020a, 2020b), DEF and ADP requested, pursuant to Section 184 of the Atomic Energy Act of 1954, as amended, and 10 CFR Sections 50.80, Transfer of licenses, and 72.50(a), Transfer of license, that the NRC consent to the transfer of DEFs licensed authority under facility operating license DPR-72 to ADP for the CR3 and the general license for the CR3 ISFSI to possess, maintain, and decommission the CR3 (ADP 2024a).

2-2 Figure 2-1 CR3 Site Map. The area outlined in yellow represents the 358-ha (884-ac)

NRC-Licensed Area (Source: ADP 2024a)

On April 1, 2020, the NRC approved the requested transfer of the CR3 from DEF to ADP to commence decontamination, dismantlement, and demolition (NRC 2020b). On October 1, 2020, ADP updated the PSDAR to change the plant decommissioning strategy from SAFSTOR to DECON1 (NRC, 2021).

ADP submitted a revised LTP request on June 9, 2023, in accordance with 10 CFR 50.82(a)(9) for the portion of CR3 that occupies approximately 11 ha (27 ac) of land in the southern half of the licensed area (ADP 2024a) (figure 2-2). On December 7, 2024, the NRC staff held a public meeting related to the LTP request in Crystal River, Florida. The meeting covered the NRCs overall processes for decommissioning and for approving the LTP and was held to receive 1 As defined in the GEIS Glossary, SAFSTOR is A method of decommissioning in which the nuclear facility is placed and maintained in a safe stable condition for a number of years until it is subsequently decontaminated and dismantled to levels that permit license termination. During SAFSTOR, a facility is left intact, but the fuel has been removed from the reactor vessel and radioactive liquids have been drained from systems and components and then processed. Radioactive decay occurs during SAFSTOR period, thus reducing the quantity of contaminated and radioactive material that must be disposed of during decontamination and dismantlement. DECON, as defined in the GEIS Glossary, is An option for decommissioning in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

2-3 public questions and comments on the LTP. The public did not make any comments or ask any questions (NRC 2023b).

Figure 2-2 CR3 Layout Map. The areas outlined in red represent the 11-ha (27-ac)

Proposed Action Area (Source: ADP 2024b) 2.1.2 Decommissioning Activities The initial phase of decommissioning activities included draining fluids and de-energizing systems and reconfiguring the electrical distribution, ventilation, heating, and fire protection systems. In January 2018, DEF completed the transfer of spent fuel to the ISFSI for dry storage.

Spent fuel racks were removed and shipped for disposal, and the spent fuel pool was cleaned out and dewatered (Duke 2018, ADP 2024a). While the spent fuel remains onsite security of the ISFSI will include a 24-hour security force, preventive and corrective maintenance on security systems, a security fence, sensors, alarms, and other surveillance equipment (ADP 2019).

ADPs subsequent decommissioning activities are associated with the removal and disposal of contaminated and activated components and structures, including the successful termination of the 10 CFR Part 50 operating license, with the exception of the portion covering the ISFSI. To decontaminate the facility, ADP has and will continue to undertake controlled removal and disposal of the components listed below. Although the initial radiation levels decreased during the dormancy period (SAFSTOR), the internal components of the reactor vessel still exhibited sufficiently high radiation dose rates for ADP to have to section it remotely underwater.

Similarly, radioactive corrosion products on the inner surfaces of piping and components had not decayed to levels that would allow either unrestricted use or conventional removal.

Therefore, ADP surveyed the components as it removed them and disposed of them in accordance with the existing radioactive release criteria. Additional significant decommissioning activities, some of which ADP has completed and some of which ADP has yet to complete, are listed below (ADP 2019):

2-4

• design and fabrication of temporary and permanent shielding to support removal and transportation activities

• procurement of shipping canisters, cask liners, and industrial packages for the disposition of low-level radioactive waste (LLRW)

• decontamination of components and piping systems, as required, to control worker exposure as well as the removal of contaminated underground piping

• removal of control rod drive housings and the head service structure from the reactor vessel head, if required

• offsite shipping of the reactor vessel head, with the control rod drive housings and head service structure in a one-piece package, might be considered

• removal, disassembly, and segmentation of the reactor internals, if necessary

• removal of the reactor vessel

• removal of the activated and contaminated portions of the concrete biological shield and accessible contaminated concrete surfaces

• removal of remaining plant systems and associated components as they become nonessential to the decommissioning program

• 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 used until residual levels indicate that the structures and equipment can be released for unrestricted access and conventional 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 volume reduction and waste treatment and/or packaged for controlled disposal at a LLRW waste disposal facility.

As discussed in ADPs LTP submittal, ADP has maintained and will continue to maintain radiological and environmental programs throughout the decommissioning process to protect occupational, public health and safety, and ensure environmental compliance with all applicable laws and regulations. ADP has conducted and will continue to conduct radiological programs in accordance with the facilitys technical specifications, operating license, Defueled Safety Analysis Report, Radiological Environmental Monitoring Program, and the Offsite Dose Calculation Manual. ADP has conducted and will continue to conduct non-radiological environmental in accordance with applicable requirements and permits. Additionally, ADP has incorporated the Final Site Survey (FSS) Plan into the LTP. This plan identifies the radiological surveys (i.e., final site surveys) ADP will perform once it completes the decontamination activities. Due to the large scope of remaining structures and systems to be decontaminated and the need for ADP to perform some (FSS) activities in parallel with dismantlement activities, if the NRC staff approves the LTP, ADPs application says it will implement a systematic approach to control the potential for re-contamination. If the NRC staff approves the LTP, ADPs

2-5 application says it will implement one or more of the following control measures: installation of barriers to control access to surveyed areas and prevent the migration of contamination from adjacent areas, installation of postings requiring personnel to perform contamination monitoring prior to surveyed area access, and installation of tamper-evident labels or seals. Upon completion of the FSS, ADP will survey the area periodically to ensure that contamination does not recur. If ADP detects re-contamination, it will initiate an investigation that could result in corrective actions, up to and including reperformance of the FSS for that area (ADP 2019).

Major Decommissioning Activities and Estimated Completion Date (ADP 2024a):

• Large Component Removal: December 2023

• Turbine Building Removal: August 2023

• Auxiliary Building: December 2024

• Intermediate Building: July 2025

• Reactor Building above grade removal: May 2025

• Site restoration: December 2026

• FSS activities: December 2026 The NRC staff understands that activities related to both large component removal and turbine building removal are ongoing. ADP has continued dismantling and decommissioning activities while the NRC reviews the LTP. Given the above-discussed approval of the partial site release request and planned partial license termination, ADP plans to release most of the CR3 site property for redevelopment.

The NRC will not terminate the CR3 license until ADP demonstrates in its final radiation survey that (1) the site meets 10 CFR 20.1402 criteria and (2) the facility has been dismantled in accordance with the approved LTP. ADP intends to complete radiological decommissioning, site restoration, and release for unrestricted use of all portions of the site other than the ISFSI in 2026 (ADP 2024a). Full NRC license termination will not occur until spent fuel and greater than class C (GTCC) waste has been removed from the site and the ISFSI is decommissioned.

2.2 Alternatives As in Section 1.3 of this EA, the NRC staff considered the no-action alternative. Under the no-action alternative, the NRC would not approve the LTP or the license amendment request because regulatory requirements have not been met. If the NRC was unable to approve the LTP because the regulatory requirements were not met, ADP would need to take additional action to prepare an LTP that meets the requirements in 10 CFR 50.82(a)(10). Under that scenario, ADP would resubmit the LTP, activities at the CR3 would likely continue, and the environmental impacts would not change as a result of the additional time required for the LTP resubmission.

As such, the no-action alternative is not evaluated in further detail.

3-1 3

AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS This section describes the current environmental conditions at the CR3 site to provide a framework, or baseline, for the evaluation of the potential environmental impacts. It also describes the environmental impacts on those resources that may be affected by the proposed action.

Table 3-1 lists impacts from environmental resource areas that are generically resolved and bounded by the Decommissioning GEIS. This EA will focus on those areas that were not generically resolved in the GEIS and therefore require site-specific analysis of potential impacts.

As discussed in section 1.4, these impacts requiring site-specific analysis are:

• offsite land use

• threatened and endangered species

• aquatic ecology beyond the operational area

• terrestrial ecology beyond the operational area

• environmental justice

• historic and cultural resources beyond the operational area Areas that were not addressed in the GEIS but will be addressed in this EA are:

• affected environment at the CR3

• climate change and GHGs

• nonradioactive waste management

• cumulative impacts Table 3-1 Environmental Resource Areas Bounded by the Decommissioning GEIS Environmental Resource Impact Considerations Land Use The NRC staff expects no impacts associated with land use beyond those discussed in the GEIS, which concluded that the impact level is SMALL. However, offsite, the GEIS notes that potential impacts may be SMALL, MODERATE, or LARGE and must be determined through site-specific analysis.

Aesthetics/Noise The NRC staff expects no impacts associated with aesthetics/noise beyond those discussed in the GEIS, which concluded that the impact level is SMALL. Activities will include restoring the site to a more natural grade in preparation for potential redevelopment. Noise will be generated primarily from typical decommissioning and demolition activities and heavy equipment use.

3-2 Environmental Resource Impact Considerations Air Quality The NRC staff expects no impacts associated with air quality issues beyond those discussed in the GEIS, which concluded that the impact level is SMALL. Air emissions such as exhaust and fugitive dust will be localized and temporary. ADP will comply with all applicable State and Federal regulations related to air emissions.

Water Use and Quality The NRC staff expects no impacts on water use or quality other than those described in the GEIS. The GEIS concluded the impacts on water quality for both surface water and groundwater indicate that for all facilities, the impacts of decommissioning will be neither detectable nor destabilizing and therefore SMALL. Groundwater and environmental monitoring programs will continue to monitor the resources during decommissioning.

Historic and Cultural Resources Within the operational area, the NRC staff expects no impacts to historic and cultural resources beyond those discussed in the GEIS, which concluded that the impact level is SMALL. However, outside of the operational area, the GEIS notes that potential impacts may be SMALL, MODERATE, or LARGE, and must be determined through a site-specific analysis.

Aquatic and Terrestrial Ecology within the Operational Area Within the operational area, the NRC staff expects no impacts to aquatic and terrestrial ecology beyond those discussed in the GEIS, which concluded that the impact level is SMALL. However, outside of the operational area, the GEIS notes that potential impacts may be SMALL, MODERATE, or LARGE and must be determined through a site-specific analysis.

Socioeconomics The NRC staff expects no socioeconomic impacts beyond those discussed in the GEIS, which concluded that the impact level is SMALL. Site-specific information included as part of the LTP was provided for the affected environment and as a baseline for the other resource evaluations.

Public and Occupational Health The NRC staff expects no impacts associated with public or occupational health beyond those discussed in the GEIS, which concluded that the impact level is SMALL. The estimated total radioactive exposure is 120 person-rem, which is well below the GEIS estimated exposure of 560 person-rem. To ensure this, as well as compliance with all NRC regulatory limits, ADP will continue to operate the Groundwater Monitoring Program and Radiological Environmental Monitoring Program.

Transportation The NRC staff does not expect impacts associated with transportation to be destabilizing or beyond those discussed in the GEIS, which concluded that the impact level is SMALL.

3.1 Land Use 3.1.1 Land Use Including Site Description and Vicinity The CR3 uses approximately 11 ha (27 ac) of previously disturbed land within the licensed boundary (figure 2-1). The portion of the CREC outside of the licensed boundary contains 430 ha (1,062 ac) of developed land and 1,488 ha (3,676 ac) of undeveloped land. The undeveloped land is primarily hardwood hammock forest and pineland, salt marches, small tidal creeks, and freshwater swamps, protected against encroachment from any other coastal development (AEC 1973; Golder Associates 2007).

3-3 There are no public access roads to areas adjacent to the plant site apart from the plant access road. Public access to the plant site is restricted with no unauthorized public access or activity allowed on property. The site boundary is posted and fenced to prevent public access, and no public roads, railways, or waterways traverse the CREC. U.S. Highway 19 (US 19) is located 2 km (1 mi) to the east of the CREC at its closest point, and State Routes 44 and 490, and County Road 495 are located to the east of US 19.

Located due south of the site, the Crystal River is used for commercial fishing and recreational watercraft. The Gulf of Mexico, from which the CR3 historically received its cooling water, is west of the plant. Fishing and recreational watercraft have unrestricted access to the Gulf of Mexico via the Crystal River. Small watercraft are prevented from entering the CR3 discharge canal by a blockade at the bulkhead line. DEF and ADP have no legal rights to any appurtenant structures which extend into the Gulf beyond the bulkhead line (ADP 2024a).

3.1.2 Land-Use Direct and Indirect Impacts 3.1.2.1 Decommissioning GEIS Determination The GEIS concludes generically that the potential land-use impacts from decommissioning activities on a nuclear plant site are SMALL, although it indicates that a site-specific analysis is necessary to determine the significance of offsite land-use impacts (NRC 2002a). Therefore, as noted above, the GEIS bounds the onsite land-use impacts for the CR3. This means, in accordance with the conclusion in the GEIS, those impacts will be SMALL.

3.1.2.2 Site-Specific Activities In its LTP application, ADP stated it does not anticipate any changes in land use beyond the site boundary during decommissioning or license termination. The CR3 site has sufficient area that has been previously disturbed (due to construction or operations activities) for use during decommissioning (ADP 2024a). Activities associated with decommissioning such as storage and staging areas would be temporary. If the LTP is approved, ADP would put best management practices (BMPs) in place to minimize the potential for sediment and erosion (ADP 2024a). ADP further stated that construction activities that would disturb greater than 0.4 ha (1 ac) of soil require application to and approval from the Florida Department of Environmental Protection (FDEP) prior to disturbing the soil. The FDEP controls significant impacts to the environment including control sediment and erosion on water courses and wetlands through regulation of construction activities.

Based on the generic determination in the Decommissioning GEIS regarding the SMALL significance of decommissioning activities on the licensees onsite land use, and on ADPs plan to limit land disturbance from decommissioning and license termination activities to onsite land acreage and commitment to use BMPs to protect soil erosion from adjoining offsite lands, the NRC staff concludes that the potential offsite land-use impacts of decommissioning activities would be minimal.

3.2 Visual and Scenic Resources/Aesthetics 3.2.1 Description of the Visual and Scenic Affected Environment The site vicinity consists of mostly flat plains, but barrier islands, coastal lagoons, marshes, and swampy lowlands along the Atlantic Gulf coast also are present (EPA 2024). The CR3 and its

3-4 supporting structures cannot be seen from publicly accessible areas in the vicinity of the site or from US 19 (Google Earth 2019). However, the most prominent structures at the CR3 (e.g.,

auxiliary buildings, the containment structure) are the same ones that ADP will remove during decommissioning. The ISFSI, which willremain after decommissioning, is not visible offsite.

3.2.2 Visual and Scenic Resources Direct and Indirect Impacts 3.2.2.1 Decommissioning GEIS Determination Temporary (e.g., noise and dust) and permanent (e.g., viewsheds) aesthetic impacts would result from ongoing decommissioning activities. Licensees are expected to use BMPs to control dust and noise. The removal of structures is generally considered beneficial to aesthetics (NRC 2002a). The GEIS states that aesthetic impacts for the DECON method of decommissioning would remain the same or similar to those impacts that occurred during the operational period in the case where the licensee maintains the structures throughout the decommissioning period (NRC 2002a). The NRC staff expects no aesthetic impacts beyond those discussed in the Decommissioning GEIS, which concluded that for all types of nuclear power plants, the impacts on aesthetics are SMALL and mitigation is not warranted.

3.2.2.2 Site-Specific Activities Once the major CR3 structures are removed for decommissioning, there would be a more open view of the Gulf of Mexico from the CR3 site. ADP plans to restore the site to a more natural grade and landscape as needed (ADP 2024a). License termination would not involve construction activities, land disturbance, excavation, or physical changes to the ISFSI site or physical environment.

3.3 Climatology, Meteorology, and Air Quality 3.3.1 Description of Site Climatology and Meteorology The CR3 is located within the CREC in Citrus County, Florida. The climate is characterized as humid and subtropical with dry winters, rainy summers, and mostly sunny days. Because of the proximity of CR3 to the western Gulf of Mexico coast, temperatures at the site are moderated relative to locations further inland and typically range between 45 degrees Fahrenheit (°F)

(7 degrees Celsius [°C]) and 90 °F (32°C). Temperatures in Citrus County rarely fall below 31 F

(-1°C) or above 94°F (34°C) (ADP 2024a). Average daily high temperatures during the summer season, which lasts five months from mid-May to October, are above 86°F (30°C). From early December to late February, the site experiences cooler temperatures with an average daily high below 73°F (23°C), and regular occurrences of fog. January is the coldest month with an average low of 45°F (7°C) and average high of 69°F (21°C) (ADP 2024a).

Because of the CR3s coastal location, wind direction changes frequently. February is the windiest month with an average hourly wind speed of 14.3 kilometers per hour (km/hr)

(8.9 miles per hour [mph]). Wind speeds are higher in September to mid-May, and calmer from mid-May to late-September. Calmest conditions are experienced in July with an average hourly wind speed of 9.7 km/hr (6 mph).

The annual average precipitation for the region is approximately 113 centimeters (cm)

(44.5 inches [in]) (ADP 2024a). Snowfall and icing are rarely experienced due to warm temperatures. July has the most precipitation (18.3 cm [7.2 in]) while January has the least

3-5 precipitation (5.3 cm [2.1 in]) (ADP 2024a). There is an average of 71 days with rain annually, with the most rainfall in the summer months and the least rainfall in the winter months.

Citrus County also is subject to severe storms, mostly originating in the Gulf of Mexico.

Thunderstorms frequently occur during afternoons from June to October. Tropical storms, including hurricanes originating in the warm Caribbean waters and approaching from the Gulf of Mexico, or, less frequently, across the Florida peninsula, have impacted Citrus County (NRC 2011). The strongest tropical cyclone recorded for Citrus County was Category 3 Hurricane Donna in 1960 (ADP 2024a).

There is medium potential for tornadoes during severe storms and spin-off tornadoes during a hurricane. There have been 42 tornadoes reported inCitrus County since 1950, with the strongest being an F3 on the Fujita scale in 1983 (NCEI 2024). Tornado damage has been reported in Citrus County and surrounding counties. Five recorded tornadoes beginning in the city of Crystal River occurred in 1993, 1998, and 2001 (NCEI 2024).

3.3.2 Description of Site Air Quality Citrus County is within the West Central Florida Intrastate Air Quality Control Region (AQCR)

(40 CFR Part 81). This AQCR and the rest of the state of Florida are currently in attainment for all Primary National Ambient Air Quality Standards (40 CFR 81.310).

The NRC-licensed boundary contains two operating coal-fueled power generation units that are planned to continue operation after the CR3 decommissioning is complete. Coal deliveries for these two units occur via barge two to three times per week and will continue until rail line repairs are complete in summer 2024 (ADP 2024b). Approximately 0.8 km (0.5 mi) east of the NRC-licensed boundary are two natural gas combined cycle units that began operating in 2018.

Air emissions from the coal and natural gas units will continue after the CR3 decommissioning but are not impacting attainment for the National Ambient Air Quality Standards in the AQCR.

3.3.3 Greenhouse Gases and Climate Change In CLI-09-21 (NRC 2009), the Commission provided guidance to the NRC staff on addressing GHG issues in environmental reviews. That guidance directed the NRC staff to include consideration of carbon dioxide and other greenhouse gas emissions in its environmental reviews for major licensing actions under the National Environmental Policy Act. This Commission decision was issued after the Decommissioning GEIS was finalized in 2002, and as such, these topics were not addressed in the GEIS.

Decommissioning activities include vehicle traffic, demolition of structures, dismantlement and decontamination of components and systems, and movement of materials onsite and shipment offsite occurring over a period from 2020 until decommissioning is complete. Equipment, worker vehicles, and truck shipments associated with decommissioning activities emit criteria pollutants and GHGs. The NRC staff developed a generic GHG footprint for the life cycle of a reference 1,000-megawatt electric (MWe) light-water reactor with an 80 percent capacity factor, for a net electric output of 800 MWe (NRC 2014). The life-cycle footprint includes decommissioning. The generic GHG footprint can be scaled for the number of units and electrical capacity. CR3 one nuclear unit that is similar in size (914 MWe) to the generic GHG footprint and has an estimated capacity factor of 90 percent. For the generic GHG footprint, decommissioning over a 10-year period results in an estimated 19,000 metric tons (MT) (20,944 tons) carbon dioxide equivalents (CO2e) from decommissioning equipment and another 8,000 MT (8,818 tons) CO2e from the

3-6 decommissioning workforce (NRC 2014). For the CR3, this amounts to approximately 27,763 MT (30,603 tons) CO2e over a 10-year period (27,000 MT [29,762 tons] CO2e scaled to 90 percent capacity and 914 MWe, divided by 800 MWe for the reference reactor).

In 2023 the U.S. Global Change Research Program (GCRP) published its most recent report regarding the state of climate change in the nation (GCRP 2023). The Crystal River site is in the Southeast geographic region defined in the GCRP report. The GCRP characterizes the Southeast region as increasing in intensity for climate change indicators, including extreme heat, drought, extreme precipitation events, sea level change, and tropical cyclones. The Southeast region has experienced decreases in the intensity and frequency of snowfall and frost days. In Florida, there has been little change in the number of hot or cold days over the 2002-2021 period relative to the 1901-1960 period, but there has been a noticeable increase in the number of nights where temperature never falls below 70°F. This increase in the frequency and intensity of warm nights above 70°F can have a significant impact on human health and crop yields in the region. The Southeast region has experienced an increase in the number of extreme precipitation days (defined as the top 1 percent of heaviest precipitation events), the daily maximum precipitation in a 5-year period and the annual heaviest daily precipitation from 1958 to 2021 (GCRP 2023). These changes lead to increases in river and stream flooding. The Southeast region experiences the most frequent and costly weather-related disasters, typically caused by hurricanes, and these disasters are worsening due to climate change. Hurricanes are more likely to slow down or stall near the coasts, leading to increased flooding although it is uncertain whether the slow-down of tropical storms and hurricanes is related to climate change.

A higher frequency of compound flooding (flooding caused by extreme rainfall coupled with ocean water inundation due to high tides or storm surge) by midcentury is predicted in regions along the Atlantic coast. The relative sea level rose by 15 cm (6 in.) during the 1970-2020 period as indicated by tide gauges throughout the Southeast region. The average range of sea level rise in the Southeast region by 2050 relative to 2000 is 41-58 cm (16-23 in.). Because of rising sea levels, saltwater intrusion has already degraded the health of coastal forests and estuaries, and increased soil salinity has caused decreased crop yields.

Higher temperatures also have led to an increase in the occurrence of drought in the region, with the Southeast being subject to extreme drought. Longer-term droughts appear to be increasing in severity but not frequency. The prevalence of invasive species due to climate change has resulted in crop yield losses and damaged productive natural ecosystems.

Agriculture has been threatened by strong winds from hurricanes and tropical storms and increased rainfall in coastal areas.

Climate change is projected to increase particulate matter, smog, and wildfire emissions due to increasing temperatures, leading to the highest regional projection of premature deaths across the United States due to climate-induced increases in PM2.51 and ozone exposure (GCRP 2023).

Rising temperatures due to climate change could lead to increases in harmful algal blooms, changes in geographic distribution of disease-carrying mosquitos and ticks, and decreased soil moisture leading to heightened wildfire risk, all having significant negative health impacts for residents in the Southeast.

1 PM2.5 describes fine inhalable particles, with diameters that are generally 2.5 microns and smaller.

3-7 3.3.4 Direct and Indirect Impacts on Air Quality 3.3.4.1 Decommissioning GEIS Determination Section 4.3.4 of the GEIS lists several activities that could impact air quality during decommissioning. Decommissioning activities include vehicle traffic, demolition of structures, dismantlement and decontamination of systems, and movement of materials onsite and shipment offsite occurring until decommissioning is complete. The GEIS concluded that impacts on air quality from decommissioning are SMALL. The NRC staff expects no impacts on air quality other than those described in the GEIS (NRC 2002a).

3.3.4.2 Site-Specific Activities Equipment, worker vehicles, and truck shipments emit criteria pollutants and GHGs. Structure demolition and dismantlement and truck traffic cause fugitive dust emissions. Emissions from decommissioning are localized and temporary. Equipment and processes onsite may be subject to regulation by the FDEP. The minimal air emissions from the CR3 are exempt from Title V permitting, but other sources of air emissions at the CREC are regulated by a Title V Air Operations Permit (ADP 2024b) that will remain in place during decommissioning (Duke 2013).

ADP anticipates emissions from worker vehicle traffic, although the number of employees has decreased from about 600 since before the CR3 stopped operations to approximately between 80 and 200 employees and contractors currently performing decommissioning activities (ADP 2024b). After decommissioning is complete, the workforce would be approximately 30 workers, which is much lower than the workforce present during operations (ADP 2024b). Most of the workforce commutes from the local area near the site. When decommissioning is complete, both the amount of worker vehicle traffic and truck traffic would be lower than when the CR3 was in operation with a corresponding decrease in vehicle emissions. Waste would be shipped by truck, rail, and barge, but most of the waste would be shipped by rail (ADP 2024b). ADP would comply with all applicable Federal and State regulations related to air emissions and would implement BMPs to minimize particulate matter and fugitive dust during demolition and decommissioning.

Regarding GHGs, as mentioned above, for decommissioning the CR3 over a 7-year period, the NRC staff expects decommissioning equipment and the decommissioning workforce to emit approximately 27,763 MT (30,603 tons) CO2e. ADP began decommissioning in 2020 and expects to be done in 2026 so the 10-year estimate is bounding for the CR3 because the annual emissions would occur for fewer years. Total emissions of 27,763 MT (30,603 tons) CO2e over a 10-year period amounts to 2,776 MT (3,060 tons) CO2e annually. Under 40 CFR Part 98, facilities must report emissions annually to the Environmental Protection Agency (EPA) if they emit 25,000 MT or more per year of CO2e. The 2,776 MT (3,060 tons) CO2e expected from the CR3 annually is far below the EPAs reporting threshold. Given that GHG emissions during decommissioning would be localized and temporary and well below the EPA-GHG-reporting threshold, the NRC staff concludes that the proposed actions impact on GHG would be minimal.

Even though GHG emission estimates from decommissioning are far below the EPA GHG-reporting threshold, the licensee could consider measures that would reduce GHG emissions.

These could include use of low-GHG-emitting vehicles and other policies to reduce GHG emissions from vehicle use (e.g., anti-idling policies, vanpooling, or carpooling). Maintenance of on-road construction vehicles and off-road construction equipment would also minimize daily GHG emissions.

3-8 As discussed above, climate change may lead to extreme heat, drought, river and stream flooding and sea level rise, and decreases in air quality in the region. Decommissioning activities at CR3 have minimal water use needs and would not contribute further to drought impacts or flooding and sea level rise. In a higher temperature environment, the formation of ozone due to emissions of nitrogen oxides from onsite equipment may increase. However, air emissions due to decommissioning activities are localized and temporary and unlikely to contribute measurably to ozone formation. Therefore, when the impact of the proposed action is combined with the impacts of climate change, the proposed action has minimal impacts on the relevant environmental resources.

3.4 Noise 3.4.1 Description of Noise Levels The CR3 is located on the Gulf of Mexico and there are no residences or public areas within 4.8 km (3 mi) of the site. There are no schools, hospitals, prisons, motels, or hotels in the immediate vicinity of the site. The nearest community is Crystal River, Florida, located approximately 8 km (5 mi) to the southeast of CR3. Commercial and residential development along the US 19 corridor is greater than 5.6 km (3.5 mi) east of the CR3. The community of Yankeetown is located approximately 6.9 km (4.3 mi) north of the CR3.

3.4.2 Noise Direct and Indirect Impacts 3.4.2.1 Decommissioning GEIS Determination Noise would be generated primarily from demolition activities and heavy equipment. Rail and truck shipments also would generate noise. Most other license termination activities (e.g., site radiological surveys and scans) would not generate noise. The staff expects no impacts on noise other than those described in the GEIS. The GEIS concluded that impacts on noise from decommissioning are SMALL.

3.4.2.2 Site-Specific Activities Noise from the shipment of waste would be minimal because shipment is primarily by rail, and rail shipments from the CR3 would be a small fraction of the normal rail transport volume (ADP 2024b). Noise associated with decommissioning and shipment of waste is temporary and is not expected to present an audible intrusion on the surrounding community (ADP 2024a). Consistent with the GEIS conclusion, the NRC staff expects that because of the distance of the CR3 from the nearest communities, there would be no noise impacts experienced by sensitive receptors. The ISFSI would continue operating after license termination. The ISFSI is a passive facility, and there would be only minimal noise from its operation. Given the location, noise receptors are minimal; therefore, any increase in noise as the result of the decommissioning activities would be minimal and temporary and will not exceed the impacts described in the GEIS.

3.5 Geology and Soils 3.5.1 Regional and Site-Specific Geology Within the region, subsurface rocks are fractured and susceptible to dissolution from rainwater infiltration. This subsurface geomorphology is known as a karst system. The onsite geologic

3-9 conditions indicate that the dissolution is most prevalent in the first 30 m (100 feet [ft]) below the existing ground surface (RSCS 2016).

The area, including the elevated area where the CR3 is located, is underlain by approximately 0.9-1.5 m (3-5 ft) of a fill material. Under the fill material is native soil that consists of thinly laminated, organic sandy silts and clays. Beneath these deposits lies a lime-rich soil layer originating from the decomposition of the underlying bedrock. Bedrock at the site is encountered at approximately 6 m (20 ft) below the existing ground surface and consists of two distinct carbonate Eocene formations. The upper-most member, the Inglis Member of the Moody Branch Formation, overlies an unconformity consisting of dense silt, sands, and organic clays of variable thickness which represent an erosional surface known as the Jackson-Claiborne Unconformity, an undulatory surface ranging from an elevation of 3 m (10 ft) to an elevation of 6 m (20 ft). The surface consists of materials derived, in part, from reworked residual soils, formed from the underlying carbonate sequence (Avon Park Formation) (ADP 2024a).

There have been no significant confirmed earthquakes in or near Citrus County since 1900 (ADP 2024a).

3.5.2 Regional, Site-Specific Geology and Soils Direct and Indirect Impacts 3.5.2.1 Decommissioning GEIS Determination The Decommissioning GEIS did not include geology as resource area because current power plant locations span a number of geologic settings, and any new power plant would have its site-specific geologic conditions evaluated as part of the licensing application. Therefore, this resource area was not evaluated in the GEIS (NRC 2002a) but is included in this EA to characterize the affected environment.

3.5.2.2 Site-Specific Activities Decommissioning activities and license termination (the proposed action) would not impact the geology seismicity at the site because decommissioning activities do not require alterations to the regional or site geology. Further, the site location is already disturbed due to previous construction and operation, and all impacts are expected to be less than those of construction as evaluated in the CR3 Final Environmental Statement (AEC 1973) and temporary. According to ADP, any contaminated soils encountered would be disposed of at Waste Control Specialists (WCS), whereas uncontaminated soils may be used for fill and surface grading on the site (ADP 2024a). Impacts would occur from the temporary removal, storage, and replacement of soils onsite. ADP expects to manage the potential for small spills such as vehicle and large equipment oil leaks with BMPs so that any spills onsite are localized, quickly detected, and relatively easy to remediate. Therefore, the NRC staff concludes that impacts on soils would be temporary and not significant.

3.6 Water Resource 3.6.1 Description of Affected Environment for Surface Water The western edge of the CR3 site is the Gulf of Mexico, which historically has supplied condenser cooling water for CR3. Although the public has unrestricted access to Gulf waters, public access to the site through the Gulf is prevented by a blockade at the discharge canal bulkhead line. Crystal River is approximately 6.1 km (3.8 mi) due south of the site and is used

3-10 for commercial fishing and pleasure craft. There is a state park along the north bank of the Crystal River. The Withlacoochee River is approximately 6.1 km (3.8 mi) north of the site, with the Cross Florida Barge Canal just south of the mouth of the Withlacoochee River.

Two canals on the CR3 site lead to the Gulf of Mexico. One is an intake canal in which water from the Gulf of Mexico was taken for use at the site. The other is a discharge canal used to return water to the Gulf of Mexico if it meets National Pollutant Discharge Elimination System (NPDES) discharge permit limits (ADP 2024a). ADP takes monthly seawater samples at two locations in the discharge canal and one location at the mouth of the intake canal to ensure compliance with the NPDES permit and to monitor for accidental release of contaminants (ADP 2024a). ADP takes the two samples from the discharge canal near either end of the canal, with one sample site taken slightly northwest of the reactor building and the other sample taken at the mouth of the canal where it meets the Gulf of Mexico.

Two settling ponds (settling pond 1 and settling pond 2) onsite were historically used to store effluent from the onsite sewage treatment plant (ADP 2024a). Effluent from the station drain tank that did not meet the NPDES permit criteria was occasionally discharged to the settling ponds. The settling ponds are located between the intake and discharge canals. In 2014, soil and vegetation samples from around the banks of the ponds showed minimal contamination from reactor operation, with Cs-137 at 0.007 picocuries (pCi)/gram (g). The NRC screening level for Cs-137 is defined in table H.2 in NUREG-1757 Vol. 2 Revision 2 at 11 pCi/g (NRC 2022).

The CR3 has 28 catch basins for stormwater onsite that surround the berm area (figure 3-1).

Five interconnected basins in the southern area of the berm area release water into the intake canal while 21 catch basins release water into the discharge canal. Two basins on the east side of the berm area release water into the swamp area near the ISFSI. There is also a containment area in the northwest corner of the swamp area to collect oil and stormwater runoff from the CR3 transformer bays.

There are two storm water retention ponds on the siteStormwater Retention Pond A and Stormwater Retention Pond B. Stormwater Retention Pond A collects stormwater from the swamp area east of the berm area. A Spill Retention Basin located between the two ponds takes in drainage from Pond A with overflow going into Pond B (ADP 2024a).

3-11 Figure 3-1 Crystal River Unit 3 Storm Drain Locations (Source: ADP 2024a) 3.6.2 Direct and Indirect Impacts on Surface Water 3.6.2.1 Decommissioning GEIS Determination The GEIS states that water use dramatically decreases after plants cease operations and that the quantities of water required during decommissioning for dust abatement or spent fuel cooling are trivial compared to the quantity used during operations (NRC 2002a). The GEIS also states that stormwater runoff and erosion control are expected to be managed with BMPs to minimize surface water quality changes to nondetectable levels and that any hazardous spills onsite are localized, quickly detected, and relatively easy to remediate for decommissioning sites (NRC 2002a). The GEIS concluded that impacts on surface water use and quality from decommissioning are SMALL. The NRC staff expects no impacts on surface water use or quality other than those described in the GEIS.

3.6.2.2 Site-Specific Activities Since CR3 was shut down in 2013, all spent fuel has been moved to the onsite ISFSI; thus, no water currently is used for reactor cooling or to maintain the spent fuel pool, which has been completely dewatered. With the proposed action, the potential use of surface water during decommissioning and dismantling would be higher than previous years as the reactor was in SAFSTOR; however, the site would use far less water than was used during plant operations because most of the water used during reactor operation was for reactor cooling. Water would be used during decommissioning for pipe flushing, dust abatement, and radiation shielding.

Water used on the site during decommissioning would be taken from the intake canal, which flows in from the Gulf of Mexico. The water is either recycled and reused onsite or released

3-12 back through the discharge canal in compliance with the terms of the CR3 NPDES permit.

Consumption of potable water would decrease commensurate with the expected decrease in plant staffing as the site decommissioning progresses.

Because CR3 is built on a berm that makes it higher than the surrounding facilities, it is protected against the estimated maximum storm surge. ADP would use gravel and concrete to maintain the integrity of the berm during decommissioning activities and does not expect to alter stormwater drainage swales (ADP 2024a). Thus, decommissioning procedures are likely to have a small impact on stormwater. Stormwater catch basin sediment traps could have plant-related radionuclides and non-radiological contaminants that slowly built up over time from stormwater runoff that carried minute amounts. However, if any contamination is found, the traps would be analyzed and cleaned during decommissioning (ADP 2024a).

All water in the discharge canal eventually would be returned to the Gulf of Mexico. The discharged water would comply with the CR3 NPDES permit limits for all contaminants of concern and would not have significant impact on the water quality in the Gulf of Mexico (ADP 2024a). Potential impacts on the aquatic ecology are further discussed in Section 3.8.3.

There is no historic evidence of significant contamination of the ponds (ADP 2024a). The settling ponds have already been remediated. The settling ponds banks and soil would be surveyed prior to site release to make sure there is no residual radiological or non-radiological contamination near or above relevant regulatory limits (ADP 2024a).

The CR3 plans to reuse clean concrete debris as backfill but would remove contaminated debris to be disposed of as LLRW. Any concrete used for backfilling would have to be surveyed to ensure no contamination is released into the groundwater or nearby surface waters. There is no planned onsite disposal of contaminated material. Furthermore, water demand has generally decreased over the years since the plant was shut down. Some water would still be used for dust abatement, cleaning, and radiation shielding, along with potable water for workers.

However, the staff expects no impacts on surface water use or quality other than those described in the Decommissioning GEIS.

3.6.3 Description of Affected Environment for Groundwater Groundwater at the site occurs under both unconfined and confined conditions and is first encountered at approximately 1.7 to 2.7 m (5.5 to 9 ft) below ground surface, or 6.1 m (20 ft) below the berm areas of the site (ADP 2024a). The shallow groundwater is composed of recent sediments and Tertiary age limestone. Water recharge is primarily from rainfall that falls onto the exposed formations and infiltrates into the shallow groundwater. Deeper groundwater at the CR3 site is contained within the Inglis Limestone and Avon Park Limestone. Horizontal groundwater flow is generally west-southwest toward the Gulf of Mexico. Groundwater at the site either remains onsite or discharges into the Gulf of Mexico where it becomes surface water.

Because of the proximity of the Gulf of Mexico and seawater intrusion, groundwater onsite is too saline for use as potable water (ADP 2024a). Sampling from onsite wells shows that the groundwater contains upwards of 350 parts per million (ppm) of chlorides with a conductivity greater than 2,000 micro-siemens/cm (µS/cm). The Florida Department of Environmental Protection set the primary drinking water standard for chlorine at the EPA secondary maximum contaminant level for chlorine, which is 250 ppm. Conductivity in water is an indirect measure of the salinity as the dissolved salts increase the capacity of the water to conduct electricity. The EPA has not set a Federal regulation for water conductivity; however, the EPA secondary

3-13 drinking water standard for total dissolved solids is 500 mg/L (EPA 2024). 500 mg/L would be roughly 800-1,000 µS/cm, depending on the salts. Elevated chloride concentration and conductivity are typical for groundwater at a site near a large body of saltwater such as the Gulf of Mexico. Potable water for the site comes from three offsite wells. These wells are located 11.9 km (7.4 mi) east-southeast, 9.7 km (6.0 mi) east-southeast, and 8.5 km (5.3 mi) north of the CR3 site, respectively (ADP 2024a).

There are 13 groundwater wells on site10 are shallow and 3 are deep. The 10 shallow wells encircle the berm area, and the three deep wells are located east, southeast, and west of the berm area at sites 1, 3, and 6 (figure 3-2) (ADP 2024a).

Figure 3-2 Crystal River Unit 3 Groundwater Monitor Well Locations. Deep Wells also are installed at locations 1, 3, and 6 (Source: ADP 2024a)

In 2014, tritium was measured at concentrations of 87 and 144 pCi/liter (L) in the groundwater on the north and south sides of the settling ponds (ADP 2024a). The tritium spike around the settling pond was attributed to discharges from the station drain tank to the settling ponds (ADP 2024a). Additionally, tritium has been measured at five wells on the west and southwest side of the site. Also in 2014, the tritium levels measured in these five wells were between 88 and 427 pCi/L. The highest tritium measurement was in 2009 at well 5 (southwest of the CR3) at 1,967 pCi/L and was likely caused by hydro-demolition water used to cut open the reactor

3-14 building for replacement of a steam generator (ADP 2024a). It should be noted that these measurements are all well below the EPA regulatory limit of 20,000 pCi/L for drinking water, based on a 4 mrem/yr dose. As the onsite groundwater is naturally not potable, the measured tritium concentrations are considered very low levels. There were no known leaks at the site, and the source of the low level of tritium in groundwater sitewide is still unknown. The very low levels of tritium are the only plant-related radionuclide identified in groundwater at the site (ADP 2024a).

3.6.4 Direct and Indirect Impacts on Groundwater 3.6.4.1 Decommissioning GEIS Determination As discussed in the Decommissioning GEIS, the impact of nuclear reactor facilities on water resources dramatically decreases after operation of the plants cease. However, water still could be required for activities including fuel removal, staff changes, large component removal, and decontamination and dismantlement. This demand would decrease over time as the decommissioning process progresses. In addition, as plant staff numbers decrease, the demand for potable water also generally decreases. However, in a few cases staffing levels have temporarily increased above levels that were common for routine operations. For these short periods of time, typically during the early stages of decontamination and dismantlement activities, there may be a slight increase in demand for potable water. The GEIS concluded the impacts on water quality from nonradioactive material for both surface water and groundwater indicate that for all facilities, the impacts of decommissioning would be neither detectable nor destabilizing and therefore SMALL, and additional mitigation is not warranted (NRC 2002a).

3.6.4.2 Site-Specific Activities There is no planned groundwater remediation at the site as part of the decommissioning activities as there is no known site-related contaminants in any groundwater wells above regulatory limits that would warrant remediation (ADP 2024a).

There have been no measured amounts of gamma-emitting radionuclides or hard-to-detect radionuclides in any of the 13 onsite groundwater wells except for low levels of gross alpha.

The alpha-emitting radionuclides are expected and likely naturally occurring in the limestone strata of the site. No groundwater well has been within 1 percent of the limit in Appendix B of 10 CFR Part 20. Additionally, the groundwater wells would continue to be monitored regularly during site decommissioning to make sure no accidental release or spill negatively affects the site groundwater (ADP 2024a). ADP reports monitoring results to the NRC annually in the Annual Radiological Environmental Operating Report (ADP 2024a). For these reasons, the NRC staff anticipates no additional impacts on groundwater use or quality other than those described in the GEIS.

3.7 Historic and Cultural Resources 3.7.1 Historic and Cultural Resources Affected Environment The National Historic Preservation Act of 1966, as amended (NHPA), requires Federal agencies to consider the effects of their undertakings on historic properties. The remaining license termination and decommissioning activities at CR3 are an undertaking that could potentially affect historic properties, should such properties be present. The NHPA defines historic properties as any prehistoric or historic district, site, building, structure, or object included in, or

3-15 eligible for, inclusion in the National Register of Historic Places (NRHP). Historic properties are a subset of cultural resources that are considered during the NEPA process. Cultural resources include, but are not limited to, properties that may not be NRHP-eligible or listed; places or landscapes of traditional cultural importance; and sacred, ceremonial, and religious sites.

Construction of CR3 was started in 1968 and completed in 1976, and commercial operation began in March 1977. Construction of CR3 involved excavation to a depth of approximately 18.3 m (60 ft) below grade and then constructing the nuclear power station, backfilling around the deeper structures to form a berm (i.e., elevated area) constructed of crushed limestone that placed CR3 approximately 6.4 m (21 ft) above the surrounding structures (ADP 2024a). The CR3 stopped producing power in 2009 and was officially retired in 2013 (ADP 2024a). At present, the CR3 occupies approximately 11 ha (27 ac) of previously disturbed land within the approximately 358 ha (884 ac) licensed boundary (i.e., the controlled area) (ADP 2024a).

Additional information on the licensing history of the Crystal River Energy Complex can be found in Section 2.1.1.

Decommissioning activities within the current CR3 license boundary and areas previously disturbed by the original construction in 1968 would include the removal of all above-grade structures and some paved surfaces, decontaminating, backfilling deep basements, and removing all buried structures to a depth of 1 m (3 ft) below the ground surface from the elevated berm. There would be no disturbance to native soil or any tree clearing. In addition, there would be limited disturbances associated with settling pond 1 and the former shooting range where remedial activities have already been completed under Florida Department of Environmental Protection oversight (ADP 2024b). Furthermore, the ISFSI would remain undisturbed and under an NRC license.

The NRC staff has determined the direct area of potential effects (APE) to be the same as the 11-ha (27-ac) disturbance area. The APE for indirect effects would be the remaining approximately 347 ha (857 ac) within the 358-ha (884-ac) NRC-licensed area, or controlled area.

The NRC staff reviewed the current and historic land use within and immediately adjacent to the CR3 site. In addition, the NRC staff reviewed numerous previously conducted cultural resource surveys that covered the direct and indirect APEs and surrounding vicinities (ADP 2024b) and conducted independent research using the Florida Master Site File. From this research, one previously recorded cultural resources site, the Seaboard Coast Line Railroad (CI01455), was identified within the direct and indirect APEs.

Information from previous surveys and site records indicate that the rail line was constructed in approximately 1966 in association with the development of the Crystal River Nuclear Plant (Arbuthnot, et al 2014). The eastwest spur rail line connects the nuclear plant with the main rail line to the east and runs along the south side of West Powerline Street. The rail corridor consists of a singletrack, standardgauge railway with wooden cross ties and metal tie plates set on a bed of crushedstone ballast. At the western end of the rail line there is a loop that circles to the south and a branch that arcs to the north. Originally a straight branch to the south side of the plant, the line was altered to form a continuous loop by 1980, likely to allow trains to exit more efficiently as there appeared to be no other turnaround within the plant. The original straight branch was removed, likely at the time that the line was reconfigured. To be considered NRHP-eligible, a Florida railroad must have served a historic transportation function and have been constructed during one of Floridas historic railroad periods. NRHP eligibility must also be

3-16 supported by association with an important local historical event or person. Additionally, the railroad must retain its original appearance to a high degree (Johnston and Mattick 2001). The Seaboard Coast Line Railroad (CI01455) was built as a spur line solely to provide access to the Crystal River Nuclear Plant, never functioned as a major transportation corridor, and was constructed during the midtwentieth century, which is not considered a historic Florida railroad period (Johnston and Mattick 2001). Furthermore, the railroad lacks association with any local historical event or individual. The section of the rail line in the direct and indirect APEs has been altered since it was originally constructed, including the removal of the original rails and cross ties and the reconfiguration of the line to form a loop. Therefore, the NRC staff has determined that CI01455 is not eligible for listing on the NRHP.

The NRC staff consulted with four federally recognized Tribes that have historic or current ties to the project area to assist in identifying cultural resources within the direct and indirect APEs. The four tribes included (1) the Seminole Tribe of Florida, (2) the Seminole Nation of Oklahoma, (3) the Muscogee Nation, and (4) the Miccosukee Tribe of Florida. Those activities are further discussed in Section 4.2 as is the NRCs consultation with the Florida State Historic Preservation Officer (SHPO) and Advisory Council on Historic Preservation (ACHP).

3.7.2 Historic and Cultural Resources Direct and Indirect Impacts 3.7.2.1 Decommissioning GEIS Determination As discussed in the Decommissioning GEIS (NRC 2002a), in most cases, the amount of land required to support the decommissioning process is relatively small and is a small portion of the overall plant site. Usually, the areas disturbed or used to support decommissioning are within the operational areas of the site and typically are within the protected area. For plants where the land disturbance beyond the operational areas is not anticipated, the impacts on cultural, historic, and archaeological resources are not considered to be detectable or destabilizing. The GEIS concluded the impacts of decommissioning on historic and cultural resources within the operational area are SMALL. The staff does not anticipate any impacts beyond those discussed in the GEIS because all planned disturbances are within the CR3 operational area.

3.7.2.2 Site-Specific Activities Although the Decommissioning GEIS concluded that a site-specific inquiry was necessary for activities beyond the operational area (NRC 2002a), there would be no decommissioning activities outside of the operational area or on previously undisturbed land (ADP 2024a). As part of the LTP application and environmental report, ADP coordinated with the Florida SHPO in September 2022 (ADP 2024a). In November 2023, the Florida SHPO responded, stating that It is the opinion of this office that the proposed project will have no effect on historic properties (ADP 2024b). Furthermore, the applicant implements an internal procedure, PRG-RNV-01-015, that provides for cultural resources awareness, archaeological discovery procedures, and compliance with various local, State, and Federal regulations (ADP 2024a). Based on its cultural resources review, the NRC staff has made a determination of No Historic Properties Affected and is coordinating with SHPO for concurrence on this determination.

3-17 3.8 Ecological Resources 3.8.1 Description of Terrestrial Resources As described in NRCs draft license renewal supplemental environmental impact statement (SEIS) for the CR3 (NRC 2011), the CREC is in Citrus County in west-central Florida between the mouths of the Withlacoochee River and the Crystal River and adjacent to the Gulf of Mexico.

The site and associated transmission lines are within the Southern Coastal Plain Ecoregion, which consists of mostly flat plains and also barrier islands, coastal lagoons, marshes, and swampy lowlands along the coasts of the Gulf of Mexico and Atlantic Ocean (EPA 2002). The region was once covered by a variety of forest communities that included longleaf pine (Pinus palustris), slash pine (P. elliottii), pond pine (P. serotina), American beech (Fagus grandifolia),

sweetgum (Liquidambar styraciflua), large-flower magnolia (Magnolia grandiflora), white oak (Quercus alba), and laurel-leaf oak (Q. laurifolia), but now is predominantly slash and loblolly pine (P. taeda) (with oak-gum-cypress forest in some low lying areas), citrus groves, cattle pasture, and urban development. Much of the area adjacent to the CREC is undeveloped wetland habitat, especially near the coast, but extensive areas of pine plantations and about 360 ha (900 ac) of quarry lakes also occur in the vicinity. Terrain in the northwestern portion of Citrus County, in which the CREC is located, rises gradually from mangrove swamp and coastal marshes along the coast to gently rolling hills about 16 mi (26 km) inland. The CREC and surrounding areas are about 0.6-1.5 m (2-5 ft) above mean sea level (AEC 1973).

The CREC occupies about 1,917 ha (4,738 ac). The developed portions of the CREC occupy about 430 ha (1,062 ac) and contain the CR3, four fossil-fueled units, associated buildings, maintenance facilities, parking lots, roads, railroads, and transmission facilities. The remaining 1,488 ha (3,676 ac) are largely undeveloped and support four habitat types: (1) salt marsh, (2) hardwood hammock forest, (3) pineland, and (4) freshwater swamp (AEC 1973). Salt or tidal marshes (FNAI 1990) occur on the westernmost portion of the site along the Gulf coast in a band about 1.2-km (0.75-mi) wide and are crossed by the intake and discharge canals associated with the CR3 (Progress Energy 2008). Salt marshes are wetland habitats that are tidally influenced and dissected by many naturally occurring tidal creeks or channels. Salt marshes on the site are dominated by smooth cordgrass (Spartina alterniflora) and Roemers rush (Juncus roemerianus) (AEC 1973). Salt marshes are used by many animal species, especially wading birds such as egrets and herons (Ardeidae) (Progress Energy 2008). The CR3 Final Environmental Statement (AEC 1973) listed the following vertebrate animals as occurring in onsite salt marshes: great blue heron (Ardea herodias), white ibis (Eudocimus albus), mallard (Anas platyrhynchos), red-winged blackbird (Agelaius phoeniceus), marsh rice rat (Oryzomys palustris), round-tailed muskrat (Neofiber alleni), and American mink (Neovison vison). According to the Florida Natural Areas Inventory (FNAI 1990), typical animals of this community type include salt marsh snails (Littorinidae, Ellobiidae), periwinkle (Littorinidae), mud snails (Nassariidae), spiders, fiddler crabs (Uca spp.), marsh crab (Decapoda spp.), isopods, amphipods, diamondback terrapin (Malaclemys terrapin), saltmarsh snake (Nerodia herodia),

wading birds, waterfowl, osprey (Pandion haliaetus), rails (Rallus spp.), marsh wren (Cistothorus palustris), seaside sparrow (Ammodramus maritimus), round-tailed muskrat, and raccoon (Procyon lotor).

The U.S. Fish and Wildlife Service (FWS) National Wetland Inventory (FWS 2010) has mapped most of the undeveloped portions of the CREC as wetland. Salt marsh habitat described above is classified by the FWS as estuarine intertidal emergent and shrub/scrub wetland (Cowardin et al. 1979). Hardwood hammocks are classified as palustrine forested evergreen and deciduous wetlands. Palustrine emergent wetlands exist as patches within these habitats and within pine

3-18 flatwoods. Freshwater swamps within pine flatwoods (described above) are classified as palustrine forested evergreen and deciduous wetland by the FWS (2010). The Florida Fish and Wildlife Conservation Commission (FWC) (2009) identified a number of potentially affected terrestrial resources near the CREC including (1) American black bear range (Chassahowitzka subpopulation); (2) priority wetlands for the American alligator (Alligator mississippiensis),

American oystercatcher, Homosassa shrew (Sorex longirostris eionis), and other wildlife species of concern; (3) strategic habitat conservation areas for the bald eagle (Haliaeetus leucocephalus) and Scotts seaside sparrow (Ammodramus maritimus peninsulae);

(4) Florida Natural Areas Inventory (FNAI) conservation lands (Waccasassa Bay Preserve State Park, Crystal River Archeological State Park, Crystal River Preserve State Park, Felburn Park, Yankeetown Conservation Area, and Marjorie Harris Carr Conservation Area);

and (5) underrepresented natural communities (pine flatwoods and sandhill). These areas are all within 5 mi (8 km) of the CREC, but none are within the CREC boundary (FWC 2009).

3.8.1.1 Federally Listed Species The FWS and the National Marine Fisheries Service (NMFS) jointly administer the Federal Endangered Species Act of 1973 (ESA). The FWS manages the protection of, and recovery effort for, listed terrestrial and freshwater species, and the NMFS manages the protection of and recovery effort for listed marine and anadromous species. This section discusses these species.

The implementing regulations for section 7(a)(2) of the ESA define action area as all areas affected directly or indirectly by the Federal action and not merely the immediate area involved in the action (50 CFR 402.02). The NRC staff generated a species list dated March 11, 2024, for an action area comprising the CREC and immediately adjacent lands using the FWS Information for Planning and Conservation (IPaC) database (FWS 2024a). The action area effectively bounds the analysis of ESA-protected species and habitats because only species that occur within the action area may be affected by the Federal action. The March 2024 species list identified seven terrestrial species as potentially occurring in the action area: (1) the whooping crane, (2) Everglade snail kite, (3) red-cockaded woodpecker, (4) eastern black rail, (5) Florida scrub-jay, (6) eastern indigo snake, and (7) monarch butterfly (table 3-2). In addition, the wood stork is a terrestrial federally listed species that has been observed at CR3 and is included in this analysis (table 3-2) (ADP 2024a).

3.8.1.2 State-Listed Species The LTP identifies the several terrestrial species that are listed in the Florida Endangered and Threatened Species Act of 1977and the ESA as potentially occurring on or near the CREC as of 2023 (table 3-2) (ADP 2024a).

3-19 Table 3-2 Federally and State-Listed Terrestrial Species that May Occur Within or Near the CR3 Common Species Name Scientific Species Name Federally Listed Status State Listed Status Descriptiona Habitat(a)

Habitat Occurrence Birds Whooping crane Grus americana EXPN North Americas tallest bird, flagship species, snowy white, dark bill Migration habitat includes marshes, shallow lakes, lagoons, salt flats, grain and stubble fields, barrier islands SH Everglade snail kite Rostrhamus sociabilis plumbeus FE Mid-size raptor, males are gray, females are brown, curved bill Large, open freshwater marshes and lakes with shallow open waters SH Red-cockaded woodpecker Picoides borealis FE Only woodpecker that excavates live pines, sedentary, prefer large/older trees, Open, mature pine woodlands SH Eastern black rail Laterallus jamaicensis FT Sparrow-sized, secretive birds, gray-black coloration Salt, brackish, and freshwater marshes with vegetation SH Florida scrub-jay Aphelocoma coerulescens FT Blue and gray bird that are similar to blue jay, no black markings, diet of insects, frogs, lizards, mice, bird eggs, acorns Open, fire-maintained oak scrub without dense canopy SH Wood stork Mycteria americana FT ST Large, long-legged bird, white, black tail, head, and neck un-feathered, yellowish bill Freshwater wetlands, marshes, swamps, lagoons, ponds, flooded fields P

American Oystercatcher Haematopus palliatus ST Patterned shorebird, vivid-orange bill, diet of shellfish Beaches, sandbars, spoils islands, shell rakes, slat marches, oyster reefs SH Black skimmer Rynchops niger ST Large red and black bill that sharpens to a point, plumage is black (above) and white (below)

Estuaries, beaches, sandbars SH Florida burrowing owl Athene cunicularia floridana ST Small owl, brown with white spots, lacks ear tufts, long legs Open prairies with little floor vegetation SH

3-20 Common Species Name Scientific Species Name Federally Listed Status State Listed Status Descriptiona Habitat(a)

Habitat Occurrence Florida sandhill crane Antigone canadensis pratensis ST Grey, heron-like bird, bald red skin on top of head, long neck and legs Wet prairies, marshy lake regions, low lying pastures, shallow flooded open areas SH Least tern Sternula antillarum ST Smallest tern in North America, long pointed wings, deeply forked tail, yellow beak, gray back, white belly, black cap Coastal areas throughout Florida, beaches, lagoons, bays, estuaries SH Little blue heron Egretta caerulea ST Small wading bird, grayish-blue body, dark red/purple head Fresh, salt, brackish water, swamps, estuaries, ponds, lakes, rivers SH Marians marsh wren Cistothorus palustris marianae ST Small wren with dark brown neck, back, head, wings, tail, white band above eye, black triangle on back Marsh with black needle rush and cordgrass SH Reddish egret Egretta rufescens ST Rare, dark and white morph, diet of small fish Coastal areas, estuaries, mangroves, lagoons, dredge-spoiled islands SH Roseate spoonbill Platalea ajaja ST Endemic, pink wings, pinkish legs, no feathers on head, spoon-shaped bill Mangroves and dredge-spoiled islands SH Scotts seaside sparrow Ammodramus maritimus peninsulae ST Grayish brown upper body, long bill, short, pointed tail Tidal marshes SH Tricolored heron Egretta tricolor ST Dark colored head and upper body, purple chest, white underside, slender bill and neck Fresh and saltwater marshes, estuaries, mangrove swamps, lagoons, river deltas SH Bald Eagle Haeliaeetus leucocephalus ST White head, yellow beak, brown body Coastal areas, bays, rivers, lakes, large bodies of water SH Reptiles Eastern Indigo snake Drymarchon couperi FT Bluish-black snake, smooth scales, non-aggressive, exothermic Pine flatwoods, moist hammocks, cypress swamps SH

3-21 Common Species Name Scientific Species Name Federally Listed Status State Listed Status Descriptiona Habitat(a)

Habitat Occurrence Florida Pine snake Pituophis melanoleucus ST Large snake, brown back with dark blotches, white belly, ridged scales, pointed snout Pine flatwoods, oak scrubs, dry oak forest, old fields, ruderal habitat SH Short-tailed snake Lampropeltis extenuata ST Small, fossorial snake, gray body, smooth scales, small tail Sandy soil, longleaf pine, and xeric, oak sandhills, xeric hammock SH Gopher tortoise Gopherus polyphemus ST Stumpy hind feet, tan/brown/gray shell, flattened forelimbs, thick scales Open canopy, well-drained sandy soil with widely spaced vegetation SH Insects Monarch Butterfly Danaus plexippus CND Bright orange wings, black border, black veins, white spots Near milkweed and flowering plants, grassland, coastal, urban, rural, wetland SH (a) FWS 2023; FWC 2023; NOAA 2023 CND: Candidate, EXPN: Experimental Population, FE: Federally Endangered, FT: Federally Threatened, P: Potential Habitat Present, ST: State Threatened, FT(S/A): Federally Threatened due to Similar Appearance, SH: Suitable Habitat Present

3-22 3.8.1.3 Species Protected Under the Migratory Bird Act The FWS administers the Migratory Bird Treaty Act of 1918 (MBTA), which prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. The MBTA protects a total of 1,093 migratory bird species (85 FR 21282). The NRC staffs IPaC search identified several species of migratory birds designated as birds of priority concern by the FWS near the CREC (table 3-3).

Table 3-3 Avian Species Protected Under the MBTA Near the CR3 Common Species Name Scientific Species Name Breeding Season(a)

American Kestrel Falco Sparverius paulus Apr 1 to Aug 31 American Oyster catcher Haematopus palliatus Apr 15 to Aug 31 Audubons Shearwater Puffinus Iherminieri Mar 1 to Aug 5 Bald Eagle Haliaeetus leucocephalus Sep 1 to Jul 31 Black scoter Melanitta nigra Elsewhere Black skimmer Rynchops niger May 20 to Sep 15 Brown pelican Pelecanus occidentalis Jan 15 to Sep 30 Chimney swift Chaetura pelagica Mar 15 to Aug 25 Common loon Gavia immer Apr 15 to Oct 31 Great blue heron Ardea herodias occidentalis Jan 1 to Dec 31 Great shearwater Puffinus gravis Elsewhere Lesser yellowlegs Tringa flavipes Elsewhere Magnificent frigatebird Fregata magnificens Oct 1 to Apr 30 Pectoral sandpiper Calidris melanotos Elsewhere Pomarine jaeger Stercorarius pomarinus Elsewhere Prairie warbler Dendroica discolor May 1 to Jul 31 Red-breasted merganser Mergus serrator Elsewhere Red-headed woodpecker Melanerpes erythrocephalus May 10 to Sep 10 Ring-billed gull Larus delawarensis Elsewhere Royal tern Thalasseus maximus Apr 15 to Aug 31 Ruddy turnstone Arenaria interpres morinella Elsewhere Saltmarsh sparrow Ammodramus caudacutus May 15 to Sep 5 Short-billed dowitcher Limnodromus griseus Elsewhere Sooty tern Onychoprion fuscatus Mar 10 to Jul 31 Swallow-tailed kite Elanoised forficatus Mar 10 to Jun 30 White-winged scooter Melanitta fusca Elsewhere Willet Tringa semipalmata Apr 20 to Aug 5 Wilsons plover Charadrius wilsonia Apr 1 to Aug 20 (a) Source: FWS 2023a, Elsewhere: Species breed in habitats outside of the action area 3.8.1.4 Species Protected under the Bald and Golden Eagle Protection Act The bald eagle is protected under the Bald and Golden Eagle Protection Act of 1940. The only areas of the CREC likely to provide favorable habitat for the migratory bird species noted above

3-23 are the shoreline of the Gulf of Mexico and adjoining low-lying areas of forest and wetland vegetation. The NRC staff expects that ADP would obtain any permits required under the MBTA and the Bald and Golden Eagle Protection Act of 1940 and that impacts to bald eagles would be evaluated as part of that permitting process.

3.8.2 Direct and Indirect Impacts on Terrestrial Resources 3.8.2.1 Decommissioning GEIS Determination The Decommissioning GEIS concludes generically that the potential terrestrial impacts from decommissioning activities conducted within the operational area of a nuclear plant site are SMALL, although it indicates that a site-specific analysis is necessary to determine the significance of terrestrial ecology impacts from activities conducted outside of the operational area (NRC 2009). The Decommissioning GEIS acknowledges that lands disturbed by construction of a nuclear facility typically continue to be of low value as terrestrial habitat throughout operations and decommissioning unless the site goes into a decade-long period of low decommissioning activity (NRC 2009).

3.8.2.2 Site-Specific Activities In its PSDAR and LTP, ADP states that it envisions that all dismantlement, demolition, and waste-staging activities performed as part of decommissioning and license termination would take place within the former operational area of the CR3 site (ADP 2024a). ADP indicates that land disturbance would not be conducted in environmentally sensitive lands, such as nearby marsh, wetlands, and shorelines. Direct impacts such as clearing native vegetation or filling wetland would be restricted to the previously disturbed land (ADP 2024a).

ADP acknowledges that terrestrial habitats adjoining the operational area could be subject to indirect impacts from decommissioning and license termination activities caused by soil erosion, surface runoff, fugitive dust, vibration, and noise (APD 2023). ADP holds several environmental permits that ensure the safe and environmentally sound decommissioning activities on land to include the FDEP multi-sector general permit (FLR05I568-001), the FDEP industrial wastewater discharge permit (FL0A00004), and FDEP environmental resource permit (09-0270612-042-EI)

(ADP 2024b). ADP commits to control fugitive dust emissions through water spraying and other BMPs (ADP 2024a). The NRC staff concludes that the BMPs and water spraying proposed by ADP would effectively minimize erosion, runoff, and fugitive dust, thus preventing adverse impacts to terrestrial habitats adjacent to the operational area.

Birds and other wildlife using the wetlands and riparian lands adjoining the former operational area near Crystal River could be affected by vibration and noise generated by decommissioning and license termination activity within the operational area. Vibration resulting from the demolition of CR1 and CR2 was historically monitored at the independent spent fuel storage installation (ISFSI), as well as at the intake and discharge canals. ADP provided information on vibration from Crystal River 1 and 2 dismantlement (ADP 2024b). CR3 vibration dismantlement impacts are likely to be at levels similar to those recorded during CR1 and CR2 dismantlement.

It is reasonable to expect that wildlife using habitats near the site have generally acclimated to human activity typical of industrial sites, including vibration and noise from license termination activities. Certain decommissioning activities may generate brief noise bursts or vibration overpressure that may startle wildlife in nearby habitats. However, due to the short duration and historical presence of those activities, the NRC staff expects that these noise and vibration occurrences would be too brief to noticeably affect nearby wildlife.

3-24 3.8.2.3 Conclusion The NRC staff concludes that the overall direct and indirect impacts to terrestrial ecology would be SMALL. In general, this conclusion is based on the generic determination in the Decommissioning GEIS regarding the SMALL significance of decommissioning activities on the licensees site. The NRC staff does not expect the impacts to terrestrial ecological resources within the operational area to exceed those considered in the Decommissioning GEIS. Further, the NRC staff does not except impacts to terrestrial ecological resources outside of the operational area because decommissioning activities would occur within previously disturbed areas of the CR3 site as well as for the other reasons stated above.

3.8.3 Description of Aquatic Resources The principal aquatic habitat in the vicinity of the CR3 is Crystal Bay. As described in the license renewal SEIS (NRC 2011), Crystal Bay is a shallow estuarine embayment of the Gulf of Mexico mostly located between the Cross Florida Barge Canal (Marjorie Harris Carr Cross Florida Greenway) and the Crystal River and extending offshore for about 16 km (10 mi) (SWEC 1985).

It is located within Floridas Big Bend, which includes the coastlines between Franklin County and Pinellas County. The estuary areas of the Big Bend total over 101,000 ha (250,000 ac)

(Kilgen and Dugas 1989).

Very gentle slopes characterize the Big Bend bathymetry. These slopes increase about 3 ft (1 m) in depth per 5 mi (3 km) distance from shore (Hale et al. 2004). Crystal Bay is shallow with depths less than 3 m (10 ft) out to 3km (5 mi) from shore. Oyster reefs parallel the shore.

The bay in this area has relatively low wave energy with many rocky reef areas, oyster reefs, and seagrass beds. Salt marshes are extensive in undeveloped areas of the coast (SWEC 1985). Most oyster reefs are underwater at high tide with portions exposed at low tide (SWEC 1985). Numerous small basins created by the oyster reefs run in a north-south orientation near the CREC intake and discharge canals (Progress Energy 2008). During the tidal cycle, water levels fluctuate from 0.6 to 1.2 m (2 to 4 ft) (ReMetrix 2007). Salinities tend to be higher offshore and near the point of discharge (SWEC 1985). Nearshore waters of Crystal Bay have a salinity of 22 to 29 parts per thousand (AEC 1973), while salinities 13 to 16 km (8 to 10 mi) offshore are about 35 parts per thousand, which is a value typical of open ocean waters (National Ocean Service 2008).

Shallow estuaries are less able to store heat compared to deeper water bodies, and water temperatures fluctuate from 39°F (4°C) to 90°F (32°C) annually (EPA 1999). Annual water temperatures near the CREC intake average 71.2°F (21.8°C), ranging from 43°F (6.1°C) to 94.6°F (34.8°C) (Golder Associates 2007). Overall, the shallow waters of the Florida Big Bend have exceptional water quality and clarity (Handley et al. 2007). Land use practices such as agriculture, urbanization, and industrial development affect water quality, resulting in hydrologic alterations to watersheds that flow into the Big Bend area and result in nutrient enrichment of the estuarine and coastal waters (Mattson et al. 1988). Water quality within the estuarine areas of Citrus County is affected by increased urban stormwater runoff, seepage from onsite sanitary sewage disposal, sewage treatment plant effluent, residential use of pesticides, herbicide and fertilizers, and activities associated with commercial and leisure boating (CCBCC 2009).

A variety of habitats support an abundance of aquatic resources in Crystal Bay. Open water habitats include saltwater, tidally influenced water of variable salinities, and tidal freshwater areas. The bottom of Crystal Bay provides several benthic habitats, with their characteristics dictated by salinity, tides, and substrate. The Florida Fish and Wildlife Conservation

3-25 Commission provides habitat descriptions of the area, including artificial structures (reefs, hardened shorelines), coastal tidal rivers and streams, oyster reefs, salt marshes, submerged aquatic vegetation, and subtidal unconsolidated marine/estuary sediments (FWC 2005). Several taxa of plankton (Chlorophyta, Cyanobacteria, Chrysophyta, Phaeophyta, Rhodophyta, Holoplankton, Meroplankton, Ichthyoplankton), macrophytes and marine algae (shoal grass, widgeon grass, turtle grass, manatee grass, star grass, 46 taxa of algae), macroinvertebrates (oysters, coral, polychaetes, bivalves, amphipods, mollusks, and crustaceans), and fishes [Bay Anchovy (Anchoa mitchilli), Pigfish (Orthopristis chrysoptera), Pinfish (Lagodon rhomboids),

Polka-dot Batfish (Ogcocephalus radiatus), Red Drum (Sciaenops ocellatus), Silver Perch (Bairdiella chrysoura), Spot (Leiostomus xanthurus), Spotted Seatrout (Cynoscion nebulosus),

and Striped Mullet (Mugil cephalus)], occur near the CREC.

3.8.3.1 Marine Mammal Protection Act Congress passed the Marine Mammal Protection Act (MMPA) in 1972 in response to increasing concerns among scientists and the public that significant declines in certain species of marine mammals were caused by human activities. The MMPA established a national policy to prevent marine mammal species and population stocks from declining beyond the point where they ceased to be significant functioning elements of the ecosystems of which they are a part. Three Federal entities share responsibility for implementing the MMPA: National Oceanic and Atmospheric Administration (NOAA) Fisheries, FWS, and the Marine Mammal Commission. The waters surrounding the CR3 are known to be inhabited by the West Indian manatee, which is protected under the MMPA. The NRC staff concludes that the effects of license termination activities by the CR3 are minimal on the manatee as discussed in Section 3.8.5.

3.8.3.2 Federally Listed Species The NRC staff generated a species list on March 11, 2024, for an action area comprising the CREC and immediately adjacent lands using the IPaC database (FWS 2024). The action area effectively bounds the analysis of ESA-protected species and habitats because only species that occur within the action area may be affected by the Federal action. The FWS species list and NMFS identified 10 aquatic species designated under the ESA as potentially occurring in the action area (table 3-4). The list included two critical habitats: one proposed for the green sea turtle and one final for the West Indian manatee (table 3-5). Because manatees used the CREC discharge canal and surrounding area during the winter months as warmwater refuges, NRC staff included this species in this analysis. The CR3 LTP (ADP 2024a) and PSDARs (Duke 2013, ADP 2019) identified aquatic species potentially affected by decommissioning, which include two species of fish (Gulf sturgeon and smalltooth sawfish); five species of sea turtles (green, hawksbill, Kemps Ridley, leatherback, and loggerhead); and one crocodilian species (American alligator). Additionally, the NRC staff found that the giant manta ray (Mobula birostris), which the NMFS listed as threatened in 2018, may occur in the action area.

3.8.3.3 State-Listed Species The LTP identifies several aquatic species that are listed in the Florida Endangered and Threatened Species Act of 1977 and the ESA as potentially occurring on or near the CREC as of 2023 and may be viewed in table 3-4 (ADP 2024a).

3-26 Table 3-4 Federally and State-Listed Aquatic Species that May Occur Within or Near the CR3 Common Species Name Scientific Species Name Federally Listed Status State-Listed Status Description(a)

Habitat(a)

Habitat Occurrence Fishes Smalltooth sawfish Pristis pectinata FE Belongs to Elasmobranchs, no bones, skeleton made of cartilage, shark-like in appearance Tropical seas and estuaries, shallow, coastal waters, near freshwater systems SH Gulf sturgeon Acipenser oxyrunchus desotoi FT Hatched in freshwater, lives in ocean, bones (scuts) run along body Brackish and salt water (fall/winter), freshwater (spring/summer)

SH Giant manta ray Mobula birostris FT Filter feeder, migratory, large wingspan, fragmented populations Tropical, subtropical, temperate bodies of water, estuaries, inlets, bays, intercoastal SH Reptiles Hawksbill sea turtle Eretmochelys imbricata FE Unique beak-like mouth, only species of turtle that survives on diet mainly of sponges Shallow coastal waters with rocky bottoms, coral reefs, mangrove-bordered bays, and estuaries SH Kemps ridley sea turtle Lepidochely kempii FE Smallest sea turtle, mainly found in Gulf of Mexico Neritic habitat, muddy and sandy bottoms SH Leatherback sea turtle Dermochelys coriacea FE Largest turtle, lacks scales and hard shell, rubbery skin, highly migratory, divers Open ocean, seas, gulfs, bays, estuaries, sandy beaches SH Loggerhead sea turtle Caretta caretta FT Large head, feeds on whelks and conch, most abundant sea turtle in U.S, migratory Open ocean, bays, estuaries, lagoons, creeks, mouths of rivers SH Green sea turtle Chelonia mydas FT Largest hard-shelled sea turtle, herbivores (seagrass and algae)

In shore and near shore waters, inside reefs, bays, inlets SH American alligator Alligator mississippiensis FT(S/A)

Broad, rounded-snout reptile, color of the environment Fresh water lakes, slow-moving rivers, wetlands, brackish waters SH Amphibians Striped newt Notophthalmus perstriatus ST Reddish-orange stripe on body, red spots possible, 2-4.1 inches long Dry upland habitat, sandhill, scrub, flatwoods, ponds SH

3-27 Common Species Name Scientific Species Name Federally Listed Status State-Listed Status Description(a)

Habitat(a)

Habitat Occurrence Marine Mammals West Indian manatee Trichechys manatus FT Greyish-brown, sparse hairs, bristles about muzzle, flippers, spoon-shaped tail Shallow, slow-moving waters, rivers, estuaries, saltwater bays, canals, coastal waters SH (a) FWS 2023; FWC 2023; NOAA 2023 FE: Federally Endangered, FT: Federally Threatened, ST: State Threatened, FT(S/A): Federally Threatened due to Similar Appearance, SH:

Suitable Habitat Present

3-28 3.8.4 Direct and Indirect Impacts to Aquatic Resources 3.8.4.1 Decommissioning GEIS Determination The Decommissioning GEIS concludes generically that the potential impacts to aquatic ecology from decommissioning activities conducted within the operational area of a nuclear plant site are SMALL. It does indicate that a site-specific analysis is required to determine the significance of aquatic ecology impacts from activities conducted outside of the operational area (NRC 2002a).

The SMALL conclusion in the GEIS assumes that applicable BMPs are implemented, and that the licensee obtains and abides by necessary permits.

3.8.4.2 Site-Specific Activities In its LTP, ADP states that it would continue to maintain its existing FDEP permits and would perform decommissioning work in compliance with those permits and implement BMPs, as appropriate (ADP 2024a). The APD LTP contains BMPs that address sediment discharges and erosion to waterways and wetlands. In the LTP, ADP states that all BMPs would be in place prior to initiating decommissioning activities (ADP 2024a). Direct and indirect impacts outside of the operational area would be minimal or non-existent as ADP plans to contain decommissioning activities within previously disturbed area (ADP 2024a). Additionally, the ADP states that all disturbed areas would be stabilized with gravel, contouring, or vegetation to limit erosion and minimize runoff of soils to surface waters (ADP 2024b).

The only place on or near the CR3 where any of the species in table 3-4 may occur is Crystal Bay. During operations, ADP withdrew water from Crystal Bay to cool reactor systems and discharged heated effluent into the Gulf of Mexico. The CR3 is no longer operating; therefore, the requirement for the withdrawal of water from the Gulf of Mexico is greatly reduced.

Currently, ADP conducts periodic permitted liquid releases. The water provided to Raw Water Pump #6 is subsequently returned, along with the permitted liquid waste, to the discharge canal at the permitted discharge point (Northstar 2024). In its LTP, ADP states that the removal of intake and discharge facilities, as well as other shoreline structures, would be conducted in accordance with FDEP permits, and BMPs would be used (ADP 2024a). Additionally, ADP states that intake canal dredging would no longer be required for the CR3 due to the diminished residual heat removal requirements and the relocation of spent fuel to the ISFSI (ADP 2024a).

By letter dated May 9, 2024, ADP states that it has not yet been determined if the discharge structure would be removed; however, if any bank or canal work is planned by Duke Energy (the owner of two coal-fueled power generation units and the intake structure), the work would be completed under both State and Federal permits (ADP 2024b). Additionally, by letter dated January 24, 2022, the NMFS issued a letter stating that the 2002 CREC biological opinion is no longer applicable (NOAA 2022). Duke Energy (not the NRC licensee) has contracted and received proper permitting to modify the vertical weir wall structure in the discharge canal. This modification would permit manatees to move freely within the canal and prevent entrapment (Northstar 2024). ADP anticipates minimal runoff from associated land disturbance activities as current occupational areas of the plant would be the only areas where land would be disturbed (ADP 2024a).

3.8.4.3 Conclusion The NRC staff concludes that the direct and indirect aquatic ecology impacts of the proposed action would be SMALL. This conclusion is based, in part, on the generic determination in the Decommissioning GEIS regarding the SMALL significance of decommissioning activities on the

3-29 operational area. ADP plans to limit land disturbance from decommissioning and license termination activities to the existing operational area, maintain its FDEP permits, engage in no dredging activities, eliminate and reduce raw water requirements, and implement BMPs throughout decommissioning. These actions would protect Crystal Bay and the Gulf of Mexico from sedimentation, runoff, and fugitive dust. For the reasons stated above, the NRC staff does not expect impacts to aquatic ecological resources within the operational area exceed those discussed in the Decommissioning GEIS. Impacts to aquatic ecological resources outside of the operational area are not expected because decommissioning and license termination activities would occur within previously disturbed areas of the CR3 site.

3.8.5 Federally Protected Ecological Resources The NRC must consider the effects of its actions on ecological resources protected under several Federal statutes and must consult with the FWS or the NOAA, as appropriate, prior to acting in cases where an agency action may affect those resources. These statues include the following:

• Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. § 1531 et seq)

• Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the Sustainable Fisheries Act of 1996 (16 U.S.C. § 1801 et seq.)

• National Marine Sanctuaries Act (NMSA) (16 U.S.C. § 1431 et seq.)

This section describes the species and habitats that are federally protected under these statues and analyzes how the proposed license termination may affect these resources.

3.8.5.1 Endangered Species Act: Federally Listed Species and Critical Habitats Congress enacted the ESA in 1973 to protect and recover imperiled species and the ecosystems upon which they depend. The ESA provides a program for the conservation of endangered and threatened plants and animals (collectively, listed species) and the habitats in which they are found. The FWS and NMFS are the lead Federal agencies for implementing the ESA, and these agencies determine species that warrant listing. The following sections describe the Crystal River action area and the species and habitats that may occur in the action area under each of the agencies jurisdictions.

Section 3.8.1 of this EA describes the terrestrial action area for CR3 while Section 3.8.3 describes the aquatic action area. All construction on the terrestrial action area would occur within pre-existing and pre-disturbed lands and in accordance with existing FDEP permits and BMPs. As discussed above, the potential for fugitive dust would be minimal and mitigated with BMPs. For the aquatic action area, the NRC staff places special importance on the intake and discharge canal. In 2022, NMFS (2022) determined that the 2002 biological opinion no longer applies because the cooling water intake in now part of the Duke Energy Citrus Combined Cycle Station and is no longer in use for CR3. Duke Energy and not the NRCs licensee (ADP),

operates the intake in accordance with the programmatic biological opinion on the EPAs 2014 final rule on Section 316(b) of the Clean Water Act. Periodic intake of water through Raw Water Pump #6 and its associated periodic discharge would occur in accordance with existing NPDES permits.

3-30 3.8.5.2 Endangered Species Act: Federally Listed Species and Critical Habitats under FWS and NMFS Jurisdiction This section evaluates 18 species, and two critical habitats. Sixteen species are federally listed, one is proposed for listing under the ESA, and one is a candidate for listing. Two critical habitats are listed where one is proposed and one is final. Table 3-5 lists each of these species and critical habitats, its Federal status, and NRC determination. The NRC staff determined these species and critical habitats to be relevant to this review based on staffs analysis of the CR3 action area, available scientific literature and studies, and the results of past ESA Section 7 consultations in connection with the CR3 site. For the reasons discussed in table 3-5, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect nine listed species, has no effect on nine listed species, and has no effect on one proposed and one final critical habitat.

3-31 Table 3-5 NRC Effect Determinations for ESA-Protected Species and Habitats from the CR3 Decommissioning and License Termination Activities Under FWS and NMFS Jurisdiction Jurisdiction Species Federal Status Determination(a)

NMFS Smalltooth sawfish (Pristis pectinate)

FE No Effect. The primary threats to this species include bycatch and habitat loss (NOAA 2023). To date, smalltooth sawfish have not been observed at CREC. If present, the primary concerns for this species related to CREC would be water withdrawals and discharges. However, the cooling water intake system is now part of the Duke Energy Citrus Combined Cycle Station. Duke Energy and not the NRCs licensee (ADP), operates this system in accordance with the programmatic biological opinion on the EPAs 2014 final rule on Section 316(b) of the Clean Water Act (NMFS 2022). The CR3 would continue to intermittently withdrawal and discharge small amounts of water during the decommissioning period. These withdrawals and discharges would be regulated by the FDEP through the sites NPDES permit, and any impacts to federally listed species would be addressed under the programmatic Section 316(b) biological opinion. Nonetheless, the NRC staff finds that smalltooth sawfish, if present, would be unaffected by water withdrawals because the low flow associated with the small volume of water being withdrawn would not pose an impingement or entrainment risk. Smalltooth sawfish are unlikely to be around the discharge canal that would be affected by discharges, and continued compliance with the NPDES permit would ensure that discharges do not harm the aquatic environment. The NRCs (2011) license renewal SEIS describes that when work is performed in the intake or discharge canal, the licensee must comply with the Sea Turtle and Smalltooth Sawfish Construction Conditions that are part of the FDEPs State Programmatic General Permit. This procedure would continue to apply during the decommissioning period; however, any future dredging would be performed by Duke Energy and not the NRC licensee (ADP). Before dredging, Duke Energy would be required to obtain appropriate permits from the U.S. Army Corps of Engineers (USACE), and the USACE, as a Federal agency, would be required to consult with NMFS regarding this species, as appropriate, to address any potential impacts. For these reasons, the NRC staff concludes that the proposed action would have no effect on smalltooth sawfish.

NMFS Gulf sturgeon (Acipenser oxyrunchus desotoi)

FT No Effect. The factors that affect the conservation of this species include climate change, contaminants, dams, and dredging (NOAA 2023). If present, the primary concerns for this species related to CREC would be water withdrawals and discharges. However, the cooling water intake system is now part of the Duke Energy Citrus Combined Cycle Station. Duke Energy and not the NRCs licensee (ADP) operates this system in accordance with the programmatic biological opinion on EPAs 2014 final rule on Section 316(b) of the Clean Water Act (NMFS 2022). The CR3 would continue to intermittently withdrawal and discharge small amounts of water during the decommissioning period. These withdrawals and discharges would be regulated by the FDEP through the sites NPDES permit, and any impacts to federally listed species would be addressed under the programmatic Section 316(b) biological opinion. Nonetheless, the NRC staff finds that gulf sturgeon, if present, would be unaffected by water withdrawals because the low flow associated with the small volume of water being withdrawn would not pose an impingement or entrainment risk. Gulf sturgeon are unlikely to be around the discharge canal that would be affected by discharges, and continued compliance with the NPDES permit would ensure that discharges do not harm the aquatic environment. Any future dredging would be performed by Duke Energy and not the NRC licensee (ADP). Before dredging, Duke Energy would be required to obtain appropriate permits from the USACE, and the USACE, as a Federal agency, would be required to consult with the FWS regarding this species, as appropriate, to address any potential impacts. For these reasons, the NRC staff concludes that the proposed action would have no effect on gulf sturgeon.

3-32 Jurisdiction Species Federal Status Determination(a)

NMFS Giant manta ray (Mobula birostris)

FT No Effect. Factors that affect the conservation of this species include bycatch, harvest for international trade, and commercial fishing (NOAA 2023). Farmer et al. (2022) found that the giant manta ray is commonly found near the mouth of the Mississippi River delta and Southeastern Florida in the Gulf of Mexico. Surveys indicate that this species is located farther north and south of the action area, as well as in deeper waters than occur in the action area (Farmer et al. 2022). Therefore, this species does not occur in the action area, and the NRC staff concludes that the proposed action would have no effect on the giant manta ray.

NMFS Hawksbill sea turtle (Eretmochelys imbricata)

FE No Effect. The factors that affect the conservation of this species include bycatch in fishing gear, climate change, direct harvest of turtles and eggs, loss and degradation of nesting and foraging habitat, ocean pollution and debris, predation of eggs and hatchlings, and vessel strikes (NOAA 2023). The hawksbill sea turtle is known to occur in the action area, and NMFS (2002) addressed it in its 2002 biological opinion regarding operation of the CR3. During operation of the CR3, only one individual of this species was captured at the cooling water intake structure in November 2000, and it was released alive and unharmed (FPL 2001). In 2022, NMFS (2022) determined that the 2002 biological opinion no longer applies because the cooling water intake is now part of the Duke Energy Citrus Combined Cycle Station and is no longer in use for the CR3. Duke Energy and not the NRCs licensee (ADP) operates the intake in accordance with the programmatic biological opinion on EPAs 2014 final rule on Section 316(b) of the Clean Water Act. The CR3 would continue to intermittently withdraw and discharge small amounts of water during the decommissioning period. These withdrawals and discharges would be regulated by the FDEP through the sites NPDES permit, and any impacts to federally listed species would be addressed under the programmatic Section 316(b) biological opinion. Nonetheless, the NRC staff finds that hawksbill sea turtles, if present, would be unaffected by water withdrawals because the low flow associated with the small volume of water being withdrawn would not pose an impingement or entrainment risk. Sea turtles are unlikely to be around the discharge canal that would be affected by discharges, and continued compliance with the NPDES permit would ensure that discharges do not harm the aquatic environment. The NRCs (2011) license renewal SEIS describes that when work is performed in the intake or discharge canal, the licensee must comply with the Sea Turtle and Smalltooth Sawfish Construction Conditions that are part of the FDEPs State Programmatic General Permit. This procedure would continue to apply during the decommissioning period; however, any future dredging would be performed by Duke Energy and not the NRC licensee (ADP). Before dredging, Duke Energy would be required to obtain appropriate permits from the U.S. Army Corps of Engineers, and the USACE, as a Federal agency, would be required to consult with NMFS regarding this species, as appropriate, to address any potential impacts. For these reasons, the NRC staff concludes that the proposed action would have no effect on hawksbill sea turtles.

NMFS Kemps ridley sea turtle (Lepidochely kempii)

FE No Effect. The factors that affect the conservation of this species include bycatch in fishing gear, climate change, direct harvest of turtles and eggs, loss and degradation of nesting habitat, ocean pollution and debris, predation of eggs and hatchlings, and vessel strikes (NOAA 2023). The Kemps ridley sea turtle is known to occur in the action area, and NMFS (2002) addressed it in its 2002 biological opinion regarding operation of the CR3. During operation of the CR3, this species was regularly captured at the cooling water intake structure. For the same reasons explained above for the hawksbill sea turtle, the NRC staff concludes that the proposed action would have no effect on Kemps ridley sea turtles.

NMFS Leatherback sea turtle FT No Effect. The factors that affect the conservation of this species include bycatch in fishing gear, climate change, direct harvest of turtles and eggs, loss and degradation of nesting habitat, ocean pollution, and debris, predation of eggs and hatchlings, and vessel strikes (NOAA 2023). The leatherback sea turtle may occur in the action area,

3-33 Jurisdiction Species Federal Status Determination(a)

(Dermochelys coriacea),

Northwest Atlantic Ocean distinct population segment (DPS) and NMFS (2002) addressed it in its 2002 biological opinion regarding operation of the CR3. However, during operation of the CR3, no take of this species occurred, and this species was never observed at the site. For the same reasons explained above for the hawksbill sea turtle, the NRC staff concludes that the proposed action would have no effect on leatherback sea turtles.

NMFS Loggerhead sea turtle (Caretta caretta),

Northwest Atlantic Ocean DPS FT No Effect. The factors that affect the conservation of this species include bycatch in fishing gear, climate change, direct harvest of turtles and eggs, loss and degradation of nesting habitat, ocean pollution and debris, predation of eggs and hatchlings, and vessel strikes (NOAA 2023). The loggerhead sea turtle is known to occur in the action area, and NMFS (2002) addressed it in its 2002 biological opinion regarding operation of the CR3. During operation of the CR3, this species was regularly captured at the cooling water intake structure. In 2022, NMFS (2022) determined that the 2002 biological opinion no longer applied because the cooling water intake was from then on part of the Duke Energy Citrus Combined Cycle Station and was no longer in use for CR3. Duke Energy and not the NRCs licensee (ADP), operates the intake in accordance with the programmatic biological opinion on the EPAs 2014 final rule on Section 316(b) of the Clean Water Act. The CR3 would continue to intermittently withdraw and discharge small amounts of water during the decommissioning period. These withdrawals and discharges would be regulated by the FDEP through the sites National Pollutant Discharge Elimination System (NPDES) permit, and any impacts to federally listed species would be addressed under the programmatic 316(b) biological opinion. Nonetheless, the NRC staff finds that loggerhead sea turtles, if present, would be unaffected by water withdrawals because the low flow associated with the small volume of water being withdrawn would not pose an impingement or entrainment risk. Sea turtles are unlikely to be in the area of the discharge canal that would be affected by discharges, and continued compliance with the NPDES permit would ensure that discharges do not harm the aquatic environment. The NRCs (2011) license renewal supplemental environmental impact statement (SEIS) states that that when work is performed in the intake or discharge canal, the licensee must comply with the Sea Turtle and Smalltooth Sawfish Construction Conditions that are part of the FDEP State Programmatic General Permit. This procedure would continue to apply during the decommissioning period; however, any future dredging would be performed by Duke Energy and not the NRC licensee (ADP). Before dredging, Duke Energy would be required to obtain appropriate permits from the USACE who, as a Federal agency, would be required to consult with NMFS regarding this species, as appropriate, to address any potential impacts. For these reasons, the NRC staff concludes that the proposed action would have no effect on loggerhead sea turtles.

NMFS Green sea turtle (Chelonia mydas),

North Atlantic DPS FT No Effect. The factors that affect the conservation of this species include bycatch in fishing gear, climate change, direct harvest of turtles and eggs, loss and degradation of nesting habitat, ocean pollution and debris, predation of eggs and hatchlings, and vessel strikes (NOAA 2023). The green sea turtle is known to occur in the action area, and NMFS (2002) addressed it in its 2002 biological opinion regarding operation of the CR3. During operation of the CR3, this species was regularly captured at the cooling water intake structure. For the same reasons explained above for the hawksbill sea turtle, the NRC staff concludes that the proposed action would have no effect on green sea turtles.

FWS Whooping crane (Grus americana)

EXPN May Affect, NLAA. Several factors affect the conservation of this species, including alteration and destruction of habitat, climate change, and reduction in river flows (FWS 2023). The NRC staff concludes that whooping cranes may occur in the action area during migration to wintering grounds in Florida, as well as in the nearby

3-34 Jurisdiction Species Federal Status Determination(a)

Chassahowitzka National Wildlife Refuge (NRC 2011). All land disturbances and construction or demolition work would occur on previously disturbed land and would not affect any natural habitats where whooping cranes may occur. Potential stressors that whooping cranes could experience during the decommissioning period include noise; behavioral changes, such as avoidance, from vehicles, machinery, and general human activity; collisions with site structures and transmission lines; and effects related to herbicide application. Whooping cranes, if present in the action area, have already acclimated to regular site disturbances. Thus, continued disturbances during decommissioning would not cause behavioral changes in birds to a degree that would be able to be meaningfully measured, detected, or evaluated or that would reach the scale where a take might occur. Collision hazards would remain the same as during the operational period; to date, the NRC staff is not aware of any whooping crane injuries or mortalities on the CREC associated with birds colliding with site structures or transmission lines. The ADP would use EPA-approved herbicides according to label instructions, and licensed applicators would apply herbicides under supervision. Herbicide application would be limited to developed or maintained areas of the site. All potential effects on the whooping crane resulting from the proposed action would be discountable. Therefore, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the whooping crane.

FWS eastern indigo snake (Drymarchon couperi)

FT May Affect, NLAA. Several factors affect the conservation of this species, including habitat destruction, fragmentation, and degradation (FWC 2023). The NRC staff concludes that the eastern indigo snake may occur in the action area due to the presence of suitable habitat. All land disturbances and construction or demolition work would occur on previously disturbed land and would not affect any natural habitats where eastern indigo snakes may occur. Potential stressors that the eastern indigo snake could experience during the decommissioning period include noise; behavioral changes, such as avoidance, from vehicles, machinery, and general human activity; and effects related to herbicide application. Snakes, if present in the action area, have already acclimated to regular site disturbances. Thus, continued disturbances during decommissioning would not cause behavioral changes in this species to a degree that would be able to be meaningfully measured, detected, or evaluated. The ADP would use EPA-approved herbicides according to label instructions, and licensed applicators would apply herbicides under supervision. Herbicide application would be limited to developed or maintained areas of the site, and thus, snakes are unlikely to come into direct contact with these chemicals. ADP maintains a wildlife management program which educates plant workers on listed species. The NRC staff finds that all potential effects on the eastern indigo snake resulting from the proposed action would be discountable.

Therefore, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the eastern indigo snake.

FWS Everglade snail kite (Rostrhamus sociabilis plumbeus)

FE May Affect, NLAA. Several factors affect the conservation of this species, including the loss and degradation of wetlands, harassment from humans, and degradation of water quality (FWC 2023). The NRC staff concludes that the Everglade snail kite may occur in the action area due to the presence of wetlands, marshes, and emergent vegetation on or near the CREC. Direct impacts would be limited to the operational area as decommissioning activities will not degrade further habitat. Indirect effects such as noise and vibration may impact the Everglade snail kite as this species is known to abandon its nests if approached or spooked. The noise and vibration caused by decommissioning activities is predicted to be temporary and impacts are expected to be less than the CR1 and CR2 demolition activities. Collision hazards would remain the same as during the operational period; to date, the NRC staff is not aware of any Everglade snail kite injuries or mortalities on the CREC associated with birds colliding with site structures or transmission lines. The NRC staff finds that all potential effects on the Everglade

3-35 Jurisdiction Species Federal Status Determination(a) snail kite resulting from the proposed action would be discountable. Therefore, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the Everglade snail kite.

FWS red-cockaded woodpecker (Picoides borealis)

FE May Affect, NLAA. The primary threat to this species is the loss and deterioration of habitat (FWC 2023). The NRC staff concludes that the red-cockaded woodpecker may occur within the action area due to known reporting in Citrus County and the presence of longleaf pine and slash pine. Direct impacts would be limited to the operational area as decommissioning activities will not degrade further surrounding habitat. Indirect effects such as noise and vibration will be temporary. Collision hazards would remain the same as during the operational period; to date, the NRC staff is not aware of any red-cockaded woodpecker injuries or mortalities on the CREC associated with birds colliding with site structures or transmission lines. The NRC staff finds that all potential effects on the red-cockaded woodpecker resulting from the proposed action would be discountable. Therefore, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the red-cockaded woodpecker.

FWS eastern black rail (Laterallus jamaicensis)

FT May Affect, NLAA. Several factors affect the conservation of this species including habitat fragmentation, altered hydrology, land management, climate change, environmental contaminants, disease, altered food webs, and human disturbance (FWS 2023). The NRC staff concludes that the eastern black rail may occur within the action area due to suitable habitat present. Direct impacts would be limited to the operational area as decommissioning activities will not degrade further surrounding habitat. Indirect effects such as noise and vibration will be temporary and are expected to display similar peak overpressure when compared to CR1 and CR2 demolition.

Collision hazards would remain the same as during the operational period; to date, the NRC staff is not aware of any eastern black rail injuries or mortalities on the CREC associated with birds colliding with site structures or transmission lines. The NRC staff finds that all potential effects on the eastern black rail resulting from the proposed action would be discountable. Therefore, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the Eastern black rail.

FWS Florida scrub-jay (Aphelocoma coerulescens)

FT May Affect, NLAA. Several factors affect the conservation of this species including habitat destruction, and degradation from development and agriculture, and vehicle strikes (FWC 2023). The NRC staff concludes that the Florida scrub-jay may occur within the action area due to suitable habitat and past reporting of the species presence (NRC 2011). Notably, in 2011, the FWS (2011) issued a biological opinion to the NRC for the Florida scrub-jay related to construction and operation of two new nuclear units near the CREC site; however, these units were never constructed and, therefore, this opinion never became effective. For that project, most of the anticipated effects to the Florida scrub-jay would have resulted from construction of new transmission lines. CR3 decommissioning would not involve new transmission lines and would not involve any of the other potential impacts assessed in the FWSs 2011 biological opinion. Direct impacts of CR3 decommissioning activities would be limited to the operational area as decommissioning activities will not degrade further surrounding habitat.

Indirect effects such as noise and vibration will be temporary. Vehicle traffic around the operational area is expected to continue as decommissioning activities progress. Collision hazards would remain the same as during the operational period; to date, the NRC staff is not aware of any Florida scrub-jay injuries or mortalities on the CREC associated with birds colliding with site structures or transmission lines. The NRC staff finds that all potential effects on the Florida scrub-jay resulting from the proposed action would be discountable. Therefore, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the Florida scrub-jay.

3-36 Jurisdiction Species Federal Status Determination(a)

FWS Wood stork (Mycteria americana)

FT May Affect, NLAA. The primary threat to conservation of this species is due to agricultural expansion and altered hydrocycles, nest predation, prolonged drought, and loss of nesting trees (FWC 2023). The NRC staff concludes that the wood stork may occur within the action area due to prior reports of the species utilizing the percolation ponds and nearby wetlands of the CREC. Direct impacts would be limited to the operational area as decommissioning activities will not degrade further surrounding habitat. Indirect effects such as noise and vibration will be temporary. Collision hazards would remain the same as during the operational period; to date, the NRC staff is not aware of any wood stork injuries or mortalities on the CREC associated with birds colliding with site structures or transmission lines. The NRC staff finds that all potential effects on the wood stork resulting from the proposed action would be discountable. Therefore, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the Wood stork.

FWS Monarch Butterfly (Danaus plexippus)

CND May Affect, NLAA. Several factors affect the conservation of this species including habitat alteration, herbicide use, drought, and climate change (FWS 2023). The NRC staff concludes that the Monarch butterfly may occur within the action area due to the presence of suitable habitat. Continued preservation of the existing natural areas on site would result in positive impacts on monarch butterflies. Herbicides would only be applied according to labeled uses in developed and manicured areas of the site, and herbicides would not be applied in natural areas.

Monarchs would only have the potential to occur in the action area seasonally and infrequently, making the likelihood of herbicide exposure low. All potential effects on the monarch butterfly resulting from the proposed action would be discountable. Therefore, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the monarch butterfly.

FWS American alligator (Alligator mississippiensis)

FT(S/A) May Affect, NLAA. The factors that affect the conservation of this species include destruction and degradation of wetland habitat mainly due to human development, and predation of eggs (FWC 2023). The NRC staff concludes that alligators may occur in the action area in nearby wetland habitats. All land disturbances and construction or demolition work would occur on previously disturbed land and would not affect any natural habitats where alligators may occur. Potential stressors that alligators could experience during the decommissioning period include noise; behavioral changes, such as avoidance, from vehicles, machinery, and general human activity; and effects related to herbicide application. Alligators, if present in the action area, have already acclimated to regular site disturbances. Thus, continued disturbances during decommissioning would not cause behavioral changes in alligators to a degree that would be able to be meaningfully measured, detected, or evaluated or that would reach the scale where a take might occur. ADP would use EPA-approved herbicides according to label instructions, and licensed applicators would apply herbicides under supervision. Herbicide application would be limited to developed or maintained areas of the site, and thus, alligators are unlikely to come into direct contact with these chemicals. For these reasons, the NRC staff concludes that the proposed action may affect but is not likely to adversely affect the American alligator.

FWS West Indian manatee (Trichechys manatus)

FT No Effect. The factors that affect the conservation of this species include bycatch in fishing gear; climate change; direct harvest of turtles and their eggs; loss and degradation of nesting habitat; ocean pollution and debris; predation of eggs and hatchlings; and vessel strikes (NOAA 2022). Historically, manatees used the CREC discharge canal and surrounding area during the winter months as warmwater refuges, and Progress Energy Florida, Inc. maintained an FDEP-approved manatee protection plan to address potential effects of operation on this species (NRC 2011). However, the CR3 ceased discharging heated effluent over 9 years ago when the spent fuel cooling system was converted to use mechanical chillers to transfer the heat load to the surrounding atmosphere (Northstar 2024). Therefore, any remaining thermal effluent being discharged at CREC is from the

3-37 Jurisdiction Species Federal Status Determination(a)

Citrus Combined Cycle Station. As previously explained, the cooling water intake system is now part of the Duke Energy Citrus Combined Cycle Station. Duke Energy and not the NRCs licensee (ADP), operates this system in accordance with the programmatic biological opinion on the U.S. Environmental Protection Agencys 2014 final rule on Section 316(b) of the Clean Water Act (NMFS 2022). Duke Energy has obtained applicable permits from the USACE and State of Florida to modify the vertical weir wall structure within the discharge canal to permit manatees to move freely within the canal and not get trapped if they swim behind it at high tide (Northstar 2024).

Duke Energy tentatively plans to perform this work in Spring 2024. However, this work is not associated with the CR3 decommissioning activities and will not involve NRCs licensee (ADP). During the decommissioning period, the CR3 would continue to intermittently withdrawal and discharge small amounts of water. These withdrawals and discharges would be regulated by the FDEP through the sites NPDES permit, and any impacts to federally listed species would be addressed under the programmatic 316(b) biological opinion. Any future dredging would be performed by Duke Energy and not ADP. Before dredging, Duke Energy would be required to obtain appropriate permits from the USACE, and the USACE, as a Federal agency would be required to consult with the FWS regarding this species, as appropriate, to address any potential impacts. For these reasons, the NRC staff concludes that the proposed action would have no effect on the West Indian manatee.

Critical Habitat Green sea turtle, North Atlantic DPS P

No Effect. On July 19, 2023, NMFS proposed to designate specific areas in the marine environment as critical habitat for six DPSs of the green sea turtle, including the North Atlantic DPS that may occur in the action area (88 FR 46572). The area proposed as critical habitat for the North Atlantic DPS encompasses 1,047,564 km2 (650,926 mi2) of Sargassum habitat and 96,349 km2 (59,868 mi2) of nearshore waters in Florida, Texas, North Carolina, and Puerto Rico. Within Florida, all nearshore areas from the mean high-water line to 66 ft (20 m) depth would be part of this designation because these areas contain reproductive, migratory, and benthic foraging/resting essential features. Concurrently, the FWS proposed to designate terrestrial critical habitat for five DPSs, including 23 critical habitat units in Florida (88 FR 46376). None of these units are within Citrus County.

Because the action area does not include Crystal Bay, the proposed action would not affect the proposed critical habitat. As previously explained, the CR3 would continue to intermittently withdrawal and discharge small amounts of water during the decommissioning period. These withdrawals and discharges would be regulated by the FDEP through the sites NPDES permit, and habitat within Crystal Bay would not experience any effects from these small and intermittent withdrawals and discharges. Therefore, the NRC staff concludes that the proposed action would have no effect on proposed critical habitat of the North Atlantic DPS of green turtle.

Critical Habitat West Indian manatee F

No Effect. NMFS established critical habitat for the West Indian manatee in 1977 to include Crystal Bay and its headwaters, known as Kings Bay (50 CFR 17.95). As previously explained, the CR3 would continue to intermittently withdrawal and discharge small amounts of water during the decommissioning period. These withdrawals and discharges would be regulated by the FDEP through the sites NPDES permit, and habitat within Crystal Bay would not experience any effects from these small and intermittent withdrawals and discharges.

Therefore, the NRC staff concludes that the proposed action would have no effect on proposed critical habitat of the West Indian manatee.

(a) FWS 2023b; FWC 2023; NOAA 2023)

CND: Candidate, EXPN: Experimental Population, FE: Federally Endangered, FT: Federally Threatened, FT(S/A): Federally Threatened due to Similar Appearance, P: Proposed Critical Habitat, F: Final Critical Habitat

3-38 3.8.5.3 MSA: Essential Fish Habitat Congress enacted the MSA in 1976 to foster long-term biological and economic sustainability of U.S. marine fisheries. The MSA established and directs fishery management councils, in conjunction with NMFS, to designate areas of essential fish habitat (EFH) and to manage marine resources within those areas. EFH is the coastal and marine waters and substrate necessary for fish to spawn, breed, feed, or grow to maturity (50 CFR 600.10). For each federally managed species, the fishery management councils and NMFS designate and describe the EFH by life stage (i.e., egg, larva, juvenile, and adult). Crystal River is situated on the Gulf of Mexico, and the councils and NMFS have designated EFH for many federally managed species and life stages in this region (table 3-6). The affected area for EFH would be the same as the ESA action area described in Section 3.8.1.1. The low-volume and intermittent water withdrawals that would continue during the decommissioning period would be regulated by the FDEP through the sites NPDES permit, and these withdrawals and discharges would not measurably affect water quality or temperatures in Crystal Bay or result in the impingement or entrainment of any federally managed species or their prey. This is because of the small and intermittent nature of the withdrawals and discharges. Any future dredging would be performed by Duke Energy and not the NRC licensee (ADP). Before dredging, Duke Energy would be required to obtain appropriate permits from the USACE, and the USACE, as a Federal agency would be required to consult with NMFS regarding EFH, as appropriate, to address any potential impacts. For these reasons, the NRC staff concludes that the proposed action would result in no adverse impacts to EFH of all federally managed species and life stages designated in the area.

Table 3-6 EFH Protected Under the MSA Near the CR3 Common Name (Scientific Name)

Life Stage EFH Description(a)

Expected Effect of LTP of CR3 on EFH Red drum Red drum (Sciaenops ocellatus)

Eggs M, planktonic No Adverse Effect Larvae E, planktonic, SAV, sand/shell/soft bottom No Adverse Effect Juveniles M/E, less than 5 m, SAV, sand/shell/soft/hard bottom No Adverse Effect Adults M/E, between 1-46 m, SAV, pelagic, sand/shell/soft/hard bottom No Adverse Effect Reef fish - jacks (Carangidae)

Greater amberjack (Seriola dumerili)

Eggs M, 1-183 m, planktonic No Adverse Effect Larvae M, 1-183 m, planktonic No Adverse Effect Juveniles M, 1-183 m, planktonic No Adverse Effect Reef fish - wrasses (Labridae)

Hogfish (Lachnolaimus maximus)

Juveniles E/M, between 3-30 m, SAV No Adverse Effect Reef fish - snappers (Lutjanidae)

Schoolmaster (Lutjanus apodus)

Eggs M, less than 90 m, planktonic No Adverse Effect Larvae M, less than 90 m, planktonic No Adverse Effect Juveniles E/M, less than 90 m, hard bottoms, SAV, and mangroves No Adverse Effect

3-39 Common Name (Scientific Name)

Life Stage EFH Description(a)

Expected Effect of LTP of CR3 on EFH Gray snapper (Lutjanus griseus)

Eggs M, less than 180 m, planktonic No Adverse Effect Larvae M/E, less than 180 m, planktonic No Adverse Effect Juveniles M/E, less than 180 m, SAV No Adverse Effect Adults E/M, less than 180 m, sand/shell/soft/hard bottom No Adverse Effect Dog snapper (Lutjanus jocu)

Eggs M, planktonic No Adverse Effect Larvae M, planktonic No Adverse Effect Juvenile E/M, SAV No Adverse Effect Mahogany snapper (Lutjanus mahogoni)

Juvenile E/M, between 2-30 m, sand/shell bottom No Adverse Effect Lane snapper (Lutjanus synagris)

Larvae E/M, between 4-132 m, SAV No Adverse Effect Juveniles E/M, less than 20 m, SAV, sand/shell/soft bottom No Adverse Effect Yellowtail snapper (Ocyurus chrysyrys)

Juveniles M/E, between 1-183 m, SAV, soft bottom No Adverse Effect Adults M, between 1-183 m, hard bottom, shoals/banks No Adverse Effect Vermillion snapper (Rhomboplites aurorubens)

Juveniles M, between 1-25 m, hard bottom No Adverse Effect Reef fish - groupers (Serranidae)

Dwarf sand perch (Diplectrum bivattatum)

Juveniles M, hard bottom No Adverse Effect Rock hind (Epinephelus adscensionis)

Eggs M, 2-100 m, planktonic No Adverse Effect Larvae M, 2-100 m, planktonic No Adverse Effect Juveniles M, 2-110 m, reefs No Adverse Effect Red grouper (Epinephelus morio)

Juveniles M/E, less than 50 m, hard bottom, SAV No Adverse Effect Nassau grouper (Epinephelus striatus)

Eggs M, planktonic No Adverse Effect Larvae M, between 2-50 m, planktonic No Adverse Effect Juveniles M, SAV No Adverse Effect Black grouper (Mycteroperca bonaci)

Juveniles E/M, SAV, hard bottom No Adverse Effect Adults M/E hard bottom No Adverse Effect Gag grouper (Mycteroperca microlepis)

Juveniles M/E, less than 50 m, SAV, hard bottom No Adverse Effect Sand perch (Diplectrum formosum)

Adults M/E, 1-80 m, reefs, SAV, shoals/banks/soft bottoms No Adverse Effect Coastal migratory pelagic Spanish mackerel (Scomberomorus maculatus)

Juveniles M, less than 50 m, pelagic No Adverse Effect Adults E/M, less than 75 m, pelagic No Adverse Effect King mackerel (Scomberomorus cavalla)

Larvae M,35-180 m, pelagic No Adverse Effect Juveniles E/M, less than 9 m, pelagic No Adverse Effect

3-40 Common Name (Scientific Name)

Life Stage EFH Description(a)

Expected Effect of LTP of CR3 on EFH Adults E/M, 0-200 m, pelagic No Adverse Effect Shrimp White shrimp (Litopenaeus setiferus)

Larvae E/M, less than 64 m, plankton, soft bottom No Adverse Effect Juveniles E, soft bottom No Adverse Effect Pink shrimp (Farfantepenaeus duorarum)

Eggs M, less than 50 m, sand/shell bottom No Adverse Effect Larvae M, less than 50 m, planktonic, sand/shell bottom No Adverse Effect Juveniles E, less than 64 m, sand/shell bottom, SAV No Adverse Effect Adults M, less than 64 m, sand/shell bottom No Adverse Effect Stone Crab Florida stone crab (Menippe mercenaria)

Larvae E/M, less than 62 m, planktonic No Adverse Effect Juveniles E/M, less than 62 m, sand/shell/hard bottom, SAV No Adverse Effect Source of EFH descriptions: NOAA 2016 (a) M = marine; E = estuarine, SAV = submerged aquatic vegetation, m = depth zone in meters 3.8.5.4 National Marine Sanctuary Act: Sanctuary Resources Congress enacted the NMSA in 1972 to protect areas of marine environments that have special national significance. The NMSA authorizes the Secretary of Commerce to establish the National Marine Sanctuary System and designate sanctuaries within that system, which includes 15 sanctuaries and 2 marine national monuments, encompassing more than 9.9 million km2 (600,000 mi2) of marine and Great Lakes waters from Washington State to the Florida Keys, and from Lake Huron to American Samoa. Within these areas, sanctuary resources include any living or nonliving resources of a national marine sanctuary that contributes to the conservation, recreational, ecological, historical, educational, cultural, archaeological, scientific, or aesthetic value of the sanctuary. CR3 is situated on the Gulf of Mexico, and NOAA has not proposed or designated any sanctuaries in this area. Therefore, the NRC staff concludes that the proposed action would have no effect on sanctuary resources of national marine sanctuaries.

3.9 Socioeconomics 3.9.1 Socioeconomic Characteristics of the Site Vicinity This section describes current socioeconomic factors that have the potential to be directly or indirectly affected by the proposed LTP at CR3. The CR3 and the communities that support it can be described as a dynamic socioeconomic system. The communities supply the people, goods, and services required to conduct decommissioning activities. Decommissioning activities, in turn, supply wages and benefits for people and revenue for the community from the sale of goods and services to the CR3 project. The measure of a communitys ability to support the proposed LTP depends on its ability to respond to changing environmental, social, economic, and demographic conditions.

The region of influence is defined by the areas where the majority of the CR3 workers and their families reside, spend their income, and use their benefits, thus affecting the economic

3-41 conditions of the regions. The majority of the CR3 workers reside locally (ADP 2024b) with most socioeconomic impacts occurring in Citrus County. The largest cities in Citrus County are Crystal River, Homosassa, Floral City, and Inverness. According to the 2020 U.S. Census, there were 153,843 people in Citrus County (USCB 2023a).

Approximately 50 employees worked at the CR3 between the period when the shut down in 2009 and when decommissioning began in 2020 (ADP 2024b). ADP details the decommissioning activities that have been completed and remain to be completed at the CR3 in their revised LTP, chapter 3 (ADP 2024a). Approximately 80 to 200 workers are currently involved with decommissioning activities at the CR3, and approximately 30 workers would remain after completion of decommissioning (ADP 2024b).

3.9.2 Socioeconomic Direct and Indirect Impacts Potential socioeconomic impacts during decommissioning include increased demand for short-term housing, public services, and increased traffic due to temporary fluctuations in the size of the workforce required to implement the LTP at CR3. Any changes in employment and tax payments caused by decommissioning and license termination activities could have both direct and indirect impacts on the availability and demand for community services and housing and traffic volumes on roads in the communities around the CR3 site. Socioeconomic effects of reactor operations at CR3 have become well established over time as regional socioeconomic conditions have adjusted to the changing conditions at the CR3 and its workforce.

3.9.2.1 Decommissioning GEIS Determination According to the Decommissioning GEIS, socioeconomic impacts during decommissioning would be SMALL for all nuclear power plants. The staff identified no new or significant socioeconomic impact information during the LTP environmental review that would change the conclusion for site-specific decommissioning activities occurring at the CR3. In addition, ADP indicated that the number of workers at CR3 would continue to decline as decommissioning activities are completed (ADP 2024b). As discussed below, because of the number of workers involved, people living near the CR3 are not likely to experience any noticeable changes in socioeconomic conditions because of license termination beyond what is already being experienced.

As explained in GEIS section 4.3.12, Socioeconomics, a population change greater than 3 percent could have a detectable socioeconomic effect on local communities. Changes in the amount of taxes paid by the utility of less than 10 percent are generally not detectable, resulting in little to no change in the availability of local public services. The impact on public services during decommissioning are closely related to the tax impact on the community and are affected by the same characteristics of the nuclear power plant (size and age, tax treatment, and dependence of the local community on plant-related revenues). The impacts of plant closure, rather than the impacts from decommissioning activities, has a greater effect on the community through changing employment and demands for housing and infrastructure, or through reduced tax payments affecting the ability of local public services. Supplement 1 to the Decommissioning GEIS concluded that the socioeconomic impacts from decommissioning activities are SMALL.

3.9.2.2 Site-Specific Activities Changes in the number of workers at the CR3 during decommissioning increased from 50 workers before decommissioning to currently 80 to 200 workers. This change represents less

3-42 than 0.1percent in the Citrus County population. After decommissioning is complete, approximately 30 workers would be needed to provide security and maintain the ISFSI. A change from 80 to 200 workers during decommissioning to 30 workers after decommissioning represents less than 0.1percent in the Citrus County population and would not have a significant socioeconomic effect on local communities. Given that the change of the CR3 workers between decommissioning and license termination represent less than 0.1 percent of the Citrus County population, this change is less than the point at which the Decommissioning GEIS determined that there would be a detectable effect on the local community.

Property taxes paid annually to Citrus County for the CR3 have historically represented approximately 5 percent of Citrus Countys total tax revenue (Progress Energy 2008). Tax revenue generated by these payments goes to several county services (e.g., school district, water management district, hospital, etc.). Property tax payments for the CR3 after license termination will continue, based on assessments, for as long as ADP owns the properties.

Because CR3s property taxes represent less than 10 percent of Citrus Countys total tax revenue, the change in taxes paid due to subsequent release of the CR3 site for unrestricted use is not likely to have a significant socioeconomic effect.

For these reasons, the NRC staff expects no impact associated with socioeconomics beyond those discussed in the GEIS.

3.10 Public and Occupational Health The intent of decommissioning is to reduce radiological contamination at the site to meet the NRC requirements for unrestricted use. Potential human health hazards associated with decommissioning CR3 range from potential exposure to very low levels of radioactivity in soils to elevated levels of radioactivity within the remaining facility and support structures and systems (e.g., remaining lines and sumps).

All facilities that the NRC licenses must adhere to the radiation protection standards in 10 CFR Part 20 to protect workers and the public against potential health risks from exposure to radioactive material used, generated, and released from the licensed facility. In the GEIS, the NRC determined that the radiological impacts to public and occupational health would remain within regulatory limits.

3.10.1 Existing Radiological Conditions Occupational exposure would be limited using the ALARA principle and appropriate shielding during removal or dismantlement of contaminated media to ensure exposure for all workers is below regulatory requirements in 10 CFR 20.1201. To release the site from the license, the residual radioactivity must be below 25 mrem/year and ALARA for all potential exposure pathways to the average member of the critical group (i.e. a resident farmer) as required in 10 CFR 20.1402. ADP will use the final site survey data to show there is no plant-related contaminants remaining at the site, outside of the ISFSI, that could result in a dose at or above 25 mrem/year (ADP 2024a). ADP has a radiation protection program (RPP) in accordance with 10 CFR 20 requirements that it will continue to implement during decommissioning (ADP 2024a).

Radiological waste would be packaged and shipped offsite for disposal consistent with the regulations in 10 CFR Part 20 Appendix G. There is no proposed waste storage onsite beyond the ISFSI, which stores spent nuclear fuel and GTCC radiological waste in dry storage. The

3-43 ISFSI has been fully loaded with all spent nuclear fuel from the CR3 reactor. GTCC waste from the decommissioning efforts would be loaded into a canister and placed at the ISFSI for storage with the spent fuel (ADP 2024a). Concrete waste would be separated as contaminated or non-contaminated debris. Contaminated debris would be shipped offsite to an appropriate disposal site while non-contaminated debris may be used as backfill onsite (ADP 2024a). Debris used for backfilling would be surveyed to confirm there are no radiological or non-radiological contaminants near or above regulatory limits to make sure the material used does not contaminate the soil or groundwater. None of the contaminated debris is expected to significantly impact occupational exposure rates as most would have very low levels of contamination. For more highly contaminated debris, BMPs would be used to minimize worker exposures during packaging, storage, and transportation. Waste management is discussed further in Section 3.13.

3.10.2 Public and Occupational Dose Health and Safety Direct and Indirect Impacts 3.10.2.1 Decommissioning GEIS Determination The Decommissioning GEIS estimated occupational cumulative doses for PWRs using the DECON option to be 560-1,000 person-rem (5.6-10 person-Sv). The Decommissioning GEIS made the generic determination that the radiological impacts of decommissioning, including license termination activities, are SMALL because the expected doses will remain within regulatory limits (NRC 2002a).

In the Decommissioning GEIS, the NRC determined that the levels of radionuclide emissions were lower for facilities undergoing decommissioning compared to operating facilities. Collective doses to public members were lower than 1 person-rem (0.01 person-Sv) per year within 80 km (50 mi) of the facilities. The maximally exposed individual was estimated to receive a dose of less than 1 mrem/yr (0.01 mSv/yr), which is well within the regulatory limits of 10 CFR Part 20 (NRC 2002a).

3.10.2.2 Site-Specific Activities Much of the radioactivity at the site decayed during the years of dormancy in SAFSTOR and the subsequent DECON phase. Table 3-7 shows the total exposure of workers on site from 2013 to 2027. The data for years 2013 to 2021 are measured exposure from dosimetry onsite while years 2022 and 2027 are estimated totals based on the expected work to be done during decommissioning (ADP 2024a). Although ADP expects to complete decommissioning in 2026, it provided an estimate of worker exposure for 2025-2027. Assuming ADP completes decommissioning in 2026, the 2027 worker dose would presumably be lower than the below estimate. As, the provided estimate would bound actual worker dose, however, the NRC staff can rely on the estimate for its environmental analysis. Further, as the NRC staff would approve exposures before approving license termination, the worker dose in 2027 would be within regulatory limits. Plant personnel are not entering radiological areas for maintenance or calibration; therefore, occupational exposure would be smaller during decommissioning than during plant operation. By following the RPP and the ALARA principle, no workers would be expected to receive a dose near the occupational dose limits in 10 CFR 20.1201.

3-44 Table 3-7 CR3 Cumulative Site Exposure Year Exposure (person-rem) 2013 0.794 2014 0.696 2015 0.700 2016 14.746 2017 4.133 2018 1.215 2019 0.022 2020 2.287 2021 16.812 2022 21 2023(a) 35(a) 2024(a) 5(a) 2025-2027*

15(a)

• Estimated Exposure Source: ADP 2024a As discussed in the GEIS, the largest occupational dose would be during the removal and cutting of the internal structures of the containment building, such as the reactor building or other containment facilities that are likely to have high levels of contamination or activation products (year 2023) (NRC 2002a). These materials would be removed using remote machinery underwater to prevent unnecessary exposure to workers during decommissioning (ADP 2024a).

ADP proposes Derived Concentration Guidelines Levels (DCGLs) as acceptable levels of residual radioactivity that can be left at the CR3 to comply with unrestricted use criteria specified in 10 CFR 20.1402 (ADP 2024a). ADP developed DCGLs for all radionuclides of concern at the CR3 using two hypothetical scenarios, the resident farmer and building occupancy scenarios, outlined in NUREG/CR-5512 (NRC 2001). The hypothetical scenarios are designed to be the bounding scenarios with the highest potential dose to a member of the public at the site after license termination. As part of the NRC decision on whether to approve the LTP, the NRC staff will evaluate the adequacy of the DCGLs to provide protection for members of the public after termination of the license. ADP would submit a FSS after completing decommissioning activities and the NRC staff would review the information contained in the FSS to ensure residual radioactivity at the site would result in a dose less than 25 mrem/yr, as specified in 10 CFR 20.1402.

The proposed DCGLs for the site exceed the soil concentrations values established in the Memorandum of Understanding (MOU) between the NRC and the EPA (NRC 2002c). Although the MOU calls for consultation prior to NRC approval of an LTP when the proposed DCGLs exceed the soil concentration values in the MOU, the NRC staff has not yet initiated consultations with EPA. This is because the NRC staff is still conducting its safety review and the proposed concentrations may change. Consistent with the MOU and NRC guidance, the NRC staff will consult with EPA before approving the LTP, should approval be warranted and should the proposed concentrations trigger the consultation provisions in the MOU. If the FSS measurements show that the remaining radionuclide concentrations are above the values set forth in the MOU, then the NRC will consult with the EPA to identify and resolve any remaining issues. If the FSS measurements show that the remaining radionuclide concentrations are

3-45 below the values set forth in the MOU as well as the final approved DCGL values, then the NRC will proceed to terminate the ADP license (except for the ISFSI), and the site will be released for unrestricted use. The NRC will inform the EPA of such findings.

The Decommissioning GEIS concluded decommissioning would have a SMALL impact on occupational and public radiological and non-radiological health. The decommissioning of the CR3 site does not include any unique procedures or site-specific issues. Given that and the other reasons discussed above, NRC staff expects no impact associated with public and occupational health beyond those discussed in the GEIS.

3.11 Transportation and Traffic 3.11.1 Transportation Affected Environment Radioactive waste would be transported from the CR3 site mostly by rail and some truck shipments. The shipments to and from the plant would primarily result from shipments of radioactive wastes and nonradioactive wastes associated with dismantlement and disposal of structures, systems, and components. No public roads, railways, or waterways access the CR3 site. Road access to the CR3 is via US 19 (figure 3-3). The plant access road, West Power Line Street, intersects with US 19 about 5.6 km (3.5 mi) east of the CR3. A rail line runs parallel along W Power Line Street from the CR3 site past US 19. Survey Area EOCZ-02 is being used as the loading area for radioactive waste into rail cars. ADP estimates an average of less than one truck trip per month for waste removal over the remaining period of active decommissioning through 2026 (ADP 2024b). When trucks from the CR3 are added to the 2022 Florida Department of Transportation annual average daily traffic (AADT) count (between 10,500 and 18,000 vehicles) per day along US 19 in the vicinity of the CR3, traffic from the CR3 decommissioning activities would not be noticeable given the small number of trucks (FDOT 2022).

Because of the availability of a rail line and ADPs plan to ship most radioactive waste by rail, a substantial portion of the radioactive waste shipments would likely go to the Waste Control Specialist disposal facility in Andrews County, Texas. ADP estimates an average of less than two rail shipments per month for waste removal over the remaining period of active decommissioning through 2026 (ADP 2024b). Rail shipments from the CR3 would be a small fraction of the normal rail transport volume and provide no noticeable additional traffic impact on those railways. ADP also anticipates using a total of four barge shipments for waste removal over the remaining period of active decommissioning through 2026 (ADP 2024b). ADP would comply with all applicable NRC and U.S. Department of Transportation regulations, including the Federal Railroad Administration requirements, and would use approved packaging and shipping containers for waste shipments (ADP 2024a).

3-46 Figure 3-3 Location of W. Power Line Street and US 19 (Source: EPA 2024) 3.11.2 Transportation Direct and Indirect Impacts 3.11.2.1 Decommissioning GEIS Determination The Decommissioning GEIS addressed impacts to transporting equipment and materials offsite.

Materials discussed in the Decommissioning GEIS include LLRW, hazardous and nonhazardous wastes, and mixed waste. Radiological impacts include exposures to the public and workers along the transportation route. The GEIS states that transportation impacts include increases in traffic density, wear and tear on roadways and railways, and transportation accidents. While this analysis was primarily based on material leaving the site, those impacts would also apply to truck traffic bringing material (such as clean backfill soils) to the site (NRC 2002a). The Decommissioning GEIS estimates that shipment of LLRW by rail rather than by truck would reduce radiological impacts significantly, and that barge shipments could reduce the radiological impacts even further (NRC 2002a).

Regarding transportation accidents, the Decommissioning GEIS states that historically, the accident rate for activities at nuclear facilities has been lower than the national average for similar activities, attributed to the nuclear industry emphasis on training and procedures (NRC 2002a). The Decommissioning GEIS assumed most decommissioning waste would be

3-47 transported by truck and concluded that the radiological impacts from transportation, based on compliance with applicable regulations, would not be detectable or destabilizing.

Impacts are considered destabilizing if increased traffic causes a decrease in the level of service or measurable deterioration of affected roads can be tied directly to the activities at the site (NRC 2002a). The GEIS concluded that the impact to transportation from decommissioning is SMALL.

3.11.2.2 Site-Specific Activities The NRC expects that ADP would comply with all regulations and requirements for transport of waste and materials. Although the number of shipments and the volume of waste shipped are greater during decommissioning than during the operation of the facility, most of the waste would be transported by rail. There has been an overall increase in plant staff since decommissioning activities began in 2020. A work force between approximately 80 and 200 workers would continue through completion of decommissioning and demolition activities (ADP 2024b). However, the work force during decommissioning would be smaller than the work force needed during plant construction and routine refueling/maintenance operations (NRC 2002a).

Therefore, the overall reduction in the CR3 site employees as compared to operations should offset any small increase in decommissioning waste truck traffic. While there would be a minor temporary increase in traffic due to decommissioning activities, including commuter traffic, the traffic impacts on the larger capacity roads in the vicinity of the CR3, primarily US 19, would not be noticeable or destabilizing with minimal road wear and tear. This is true, even when accounting for the period between the end of operations and the start of decommissioning because of the ongoing traffic experienced during the construction and operation of fossil-fueled units within the CREC described in section 3.14. Traffic would decrease after license termination. Thus, the NRC staff expects no potential impacts from decommissioning activities on transportation beyond those discussed in the Decommissioning GEIS.

3.12 Environmental Justice The environmental justice impact analysis evaluates the potential for disproportionate and adverse human health and environmental effects on minority and low-income populations that could result from activities associated with the proposed action. Such effects may include human health, biological, cultural, economic, or social impacts. Minority and low-income populations are subsets of the general public residing near the CR3, and all are exposed to the same health and environmental effects generated from license termination activities at the CR3.

3.12.1 Minority Populations in the Vicinity of the CR3 Site According to the 2020 Census, about 48.5 percent of the State of Floridas population and about 14.5 of Citrus Countys population identified themselves as minority, with persons of Hispanic, Latino, or Spanish origin of any race comprising the largest minority population (USCB 2023b).

According to the 2010 Census, approximately 10.4 percent of the total population residing within Citrus County identified themselves as minority (MCDC 2023a). The largest minority population was Hispanic, Latino, or Spanish origin of any race. The percentage of the minority population residing within a 6.4-km (4-mi) radius of the CR3 site (approximately 8.3 percent) is much lower than the percentage for the State of Florida. According to the U.S. Census Bureaus 2017-2021 American Community Survey 5-Year Estimates, the percentage of the population residing within a 6.4 km (4-mi) radius of the CR3 identifying themselves as minority had decreased to 3.3 percent (approximately 10 individuals) of the total population (MCDC 2023b).

3-48 3.12.2 Low-income Populations in the Vicinity of the CR3 Site According to the U.S. Census Bureaus 2017-2021 American Community Survey 5-Year Estimates, the median household income for Florida was $61,777, while 9.3 percent of families and 13.1 percent of the state population were found to be living below the Federal poverty threshold (MCDC 2023c). The 2020 Federal poverty threshold was $26,200 for a family of four (ASPE 2023). According to the U.S. Census Bureaus 2017-2021 American Community Survey 5-Year Estimates, approximately 12 percent of individuals and 2.5 percent of families residing within a 6.4-km (4-mi) radius of the CR3 were identified as living below the Federal poverty threshold (MCDC 2023c).

3.12.3 Direct and Indirect Impacts Potential impacts caused by the termination of reactor operations, decommissioning, and license termination on minority and low-income populations near the CR3 would mostly consist of radiological effects. However, radiation doses from license termination activities associated with the proposed action would remain below regulatory limits, and no significant visual or noise impacts are expected.

3.12.3.1 Decommissioning GEIS Determination As discussed in the Decommissioning GEIS, Supplement 1, minority and low-income populations (see Sections 3.12.1 and 3.12.2) are subsets of the general public residing in the vicinity of a power plant. Potential impacts to minority and low-income populations would consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts) and radiological effects. Radiation doses during decommissioning are expected to remain well below regulatory limits. However, the environmental justice analysis conducted for the Decommissioning GEIS concluded that disproportionate and adverse human health and environmental effects must be determined on a site-specific basis.

3.12.3.2 Site-Specific Activities Socioeconomic characteristics and impacts in the vicinity of CR3 are provided in Section 3.9.1 of this EA. The maximum workforce during decommissioning is approximately 80 to 200 workers, but an overall decline is expected with approximately 30 workers remaining at the completion of decommissioning (ADP 2024b). An average of less than one truck trip per month and two rail trips per month is estimated over the course of active decommissioning. Given there would be a small monthly increase in trucks with decommissioning waste during decommissioning (relative to no trucks related to the CR3) followed by a decrease in worker vehicles (i.e., reduced commuter traffic) and trucks after decommissioning, significant disproportionate and adverse human health and environmental transportation-related effects from the license termination on minority and low-income populations residing along site access roads are not anticipated. As discussed in Section 3.4.2, the potential noise impacts from decommissioning including license termination activities are SMALL, and the NRC staff expects that noise impacts from the CR3 decommissioning activities are temporary and not expected to present an audible intrusion on the surrounding community. Apart from demolition during decommissioning, the ADP license termination activities (e.g., site radiological surveys and scans) would generate a minimal amount of noise and would not noticeably increase noise beyond the level associated with an industrial site. Therefore, noise from the proposed action would not be significant and there would be no disproportionate and adverse human health and environmental effects on minority and low-income populations.

3-49 As discussed in Section 3.3.4 of this EA, air emissions during ongoing decommissioning would be localized and temporary and unlikely to contribute measurably to relevant environmental resources. Air emissions would continue to be monitored under the current air monitoring program. Therefore, air emissions from decommissioning and license termination activities would not be significant and there would be no disproportionate and adverse human health and environmental effects on minority and low-income populations.

Based on this information and the analysis of human health and environmental impacts presented in this EA, the remaining decommissioning and license termination activities would have no disproportionate and adverse human health and environmental effects on minority and low-income populations near the CR3.

3.13 Waste Management Decommissioning generates large volumes of waste, both radioactive and nonradioactive (e.g.,hazardous, municipal, and demolition), primarily from the dismantling of buildings and equipment. Ongoing decommissioning activities at the CR3 are subject to non-NRC Federal and State of Florida regulations, permits, licenses, notifications, and approvals, including those forhazardous waste generation and disposition, handling and removal of asbestos, handling and removal of lead paint, and removal of underground storage tanks. Enclosure 4 (Historical Site Assessment) of the LTP documents historical information pertaining to events that may have resulted in contamination during the operating history of the CR3 including contaminated site structures or soils with radiological or chemical constituents (ADP 2024a). Chapter 2 of the LTP describes numerous studies, analyses, and other efforts to characterize the site in detail to determine the extent of radiological and non-radiological contamination. Chapter 3 of the LTP describes the completed and remaining decommissioning activities at the CR3 (ADP 2024a).

Responses to requests for additional information provided estimated quantities of radiological wastes and an attachment of the Waste Acceptance Grouping Identification Plan for the CR3 (ADP 2024b) that describes anticipated disposal scenarios including offsite waste disposal, onsite or offsite recycling, and beneficial reuse.

3.13.1 Radioactive Waste Large volumes of LLRW would result from decommissioning activities. These wastes would include concrete, metal, and asphalt, contaminated water, used disposable protective clothing, expended abrasive and absorbent materials, expended resins and filters, materials for contamination control, and contaminated tools and equipment (APD 2023). The largest volume of LLRW would result from activated and contaminated structures, systems, and components.

To comply with regulatory requirements in 10 CFR 20.1201 and 10 CFR 20 Appendix G, ADP may use longer-term shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling (ADP 2024a). ADP has selected the RESRAD-ONSITE computer code (Version 7.2) to model the dose from soils and volumetric concrete and its counterpart, RESRAD-BUILD (Version 3.5), to model the dose from structural surfaces.

Planning is currently underway to prepare the once-through steam generators (OTSGs) for shipment, and the forthcoming work would involve cutting the radioactive piping, which would result in a potential for the spread of contamination (APD 2023). Additionally, once the OTSGs have been shipped offsite, the Reactor Vessel Closure Head, currently stored in the reactor vessel closure head storage facility, would be brought into the OTSG storage facility for

3-50 processing (segmentation) prior to shipment (APD 2023). This activity also would have a high potential for contaminating the OTSG storage facility, which ADP would then clean up in accordance with the regulatory requirements. The segmentation would produce Class A, Class B/C, and GTCC waste.

Contaminated material would be characterized and segregated for additional offsite processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and packaged if necessary for controlled disposal at a LLRW disposal facility (ADP 2024a). LTP chapter 5 presents the FSS Plan which would be used to develop the site procedures, survey packages and instructions to perform the FSS of the CR3. The FSS Plan describes the FSS process used to demonstrate that the CR3 facility and site comply with radiological criteria for unrestricted use specified in 10 CFR 20.1402. The FSS Plan also describes methods and techniques used to implement isolation controls that prevent re-contaminating previously remediated areas, including but not limited to installation of barriers and postings to control access to surveyed areas to prevent the migration of contamination from adjacent or overhead areas from water runoff, etc. (ADP 2024a).

The NRC has adopted a waste classification system for LLRW based on its potential hazards, and has specified disposal and waste form requirements for each of the general classes of waste: Classes A, B, and C. The classifications are based on the key radionuclides present in the waste and their half-lives. In general, requirements for waste form, stability, and disposal methods become more stringent when going from Class A to Class C waste. Waste classified as GTCC exceeds the concentration limits in 10 CFR 61.55 and is generally unsuitable for near-surface disposal as LLRW, even though it is legally defined as LLRW. The NRCs regulations in 10CFR 61.55(a)(2)(iv) require that this type of waste be disposed of in a geologic repository unless approved for an alternative disposal method on a case-specific basis by the NRC (NRC 2002a).

As listed in table 3-8, the total volume of Class A, B, and C wastes and GTCC radioactive waste for disposal is estimated at 22,737.5 m3 (802,966 cubic feet [ft3]) (ADP 2024b). Class A, B, and C waste would be shipped to the WCS LLRW disposal facility in Andrews County, Texas. In January 2018, all spent nuclear fuel was transferred to the ISFSI where it will remain after CR3 is decommissioned (ADP 2024a). The ISFSI is not included within the scope of the LTP, and under the LTP, the 10 CFR Part 50 operating license will be reduced to the ISFSI. License termination would not affect the GTCC waste that would remain onsite in the CR3 ISFSI. The ISFSI will remain in operation until such time as a deep geologic repository becomes available to accept spent fuel or until other spent fuel disposal arrangements become available.

Table 3-8 Projected LLRW Disposal Volumes Waste Class Volume (m3)

Volume (ft3)

Class A Waste 22,653.5 800,000 Class B Waste 42.5 1,500 Class C Waste 24.5 866 GTCC Waste 17 600 Source: ADP 2024b Radioactive waste removed from the CR3 during decommissioning would be transported mostly by rail, some truck shipments, and even fewer barge shipments (ADP 2024a). ADP would conduct decommissioning in accordance with its Waste Acceptance Grouping Identification

3-51 Plan, process control program, health and safety program, RPP, and Offsite Dose Calculation Manual to manage the classification, processing, packaging, and removal of radioactive waste to meet the unrestricted release criteria (ADP 2024a).License termination would not affect the activities associated with radioactive waste storage at the CR3 ISFSI.

3.13.2 Nonradioactive Waste Most nonradioactive waste from decommissioning would result from removal of clean concrete and clean scrap metal. License termination would not affect the activities associated with nonradioactive waste removal activities at the CR3 because these activities are unrelated to license termination. During the remaining decommissioning period, ADP plans to segregate clean concrete debris produced during the demolition of site structures and to recycle the clean concrete debris to backfill the subsurface structures that would remain in place (ADP 2024a). All subsurface structures would be removed to a depth of 0.9 m (3 ft) below final grade. ADP would survey and release material for unrestricted disposition; for example, as scrap, for recycling, or for general disposal, or sent to an offsite NRC/Agreement State-licensed processor for radiological evaluation and appropriate disposition (ADP 2024a). Other wastes generated at the CR3 include universal wastes (e.g., light ballasts, fluorescent light bulbs, and mercury-containing thermostats and switches) generated in preparation for building demolition; hazardous wastes from legacy plant operations (e.g., solvents, lead-acid batteries, laboratory chemicals, and aerosols); and non-hazardous regulated wastes, such as tendon grease and waste oils (ADP 2024a). These waste streams are managed and disposed in accordance with applicable Federal and State regulations.

In a request for additional information response, ADP stated that, to date, approximately 3,356.5 MT (3,700 tons) of non-radiological solid (soil) waste from the former shooting range and the settling pond 1 has been disposed at the Republic Services Cedar Trail Landfill in Bartow, Florida. Construction and demolition waste would be characterized in accordance with waste acceptance criteria as well as State and Federal requirements. Concrete wastes will require characterization in accordance with the acceptable requirements of disposal facilities. Concrete that meets NRC and FDEP requirements would be used (with FDEP/permit approval) as backfill for the deeper basements that would be left in place. Concrete that may not be reused would be disposed offsite. Clean concrete that has been painted or coated would either be disposed of at Sandland of Florida Enterprises, Inc. in Hernando, Florida, or used as beneficial reuse material by Sean M. Gerrits, Inc. in Crystal River, Florida (ADP 2024b). ADP may dispose of or recycle construction and demolition waste at Citrus Sand & Debris in Homosassa, Florida (ADP 2024b).

To date, some demolition debris (i.e., cabling materials, pavement, wood, and piping) has been recycled using the Scrap King facility in Tampa, Florida (ADP 2024b).

3.13.3 Waste Management Direct and Indirect Impacts 3.13.3.1 Decommissioning GEIS Determination Disposal of high-level radioactive waste is beyond the scope of the Decommissioning GEIS (NRC 2002a). Regarding LLRW, the Decommissioning GEIS (Section 4.3.18) did consider the volume of land required for LLRW disposal (NRC 2002a). The Decommissioning GEIS estimated the volume of land required for radioactive waste disposal as an irretrievable and irreversible impact. In table 4-7 of the Decommissioning GEIS, it was estimated that for DECON, 8,000 to 10,000 m3 (282,500 to 353,000 ft3) of land would be needed for disposal of LLRW for a PWR larger in plant size (1,130 to 1,825 MWe) than the CR3 (914 MWe) based on previously decommissioned facilities. Because the volume of waste was underestimated for this

3-52 site, the following section provides site-specific details used by the NRC staff to determine the impact of the FCS LLRW disposal.

3.13.3.2 Site-Specific Activities As described in section 3.13, the volume of LLRW being generated at the CR3 (22,737.5 m3

[802,966 ft3]), is much greater than the volume of that assumed in the Decommissioning GEIS, Supplement 1. Table 3-9 summarizes the estimated volumes of LLRW waste going to the WCS LLRW disposal facility as well as the facilitys capacity. The CR3 LLRW estimated volume of 22,720.5 m3 (802,366 ft3) represents approximately 3 percent of WCSs capacity for LLRW (WCS 2024).

Table 3-9 Summary of LLRW Disposal Facilities and Capacities Disposal Facility Capacity CR3 LLRW Volume for Disposal Percent of Capacity Needed for the CR3 Waste WSC 736,238 m3 (26,000,000 ft3) 22,720.5 m3 (802,366 ft3) 3.08 Source: WCS 2024 Because waste from the CR3 represents such a small percentage of the overall capacity of WCSs facility, disposal of waste from the CR3 would not create a destabilizing impact on the capacity of the WCS facility. The NRC staff concludes that although remaining decommissioning activities, site remediation, and final site radiological surveys are or will generate a significant amount of LLRW waste, this amount of waste for decommissioning the CR3 site would not have a destabilizing effect on the overall disposal capacity at the WCS facility. It is worth noting that as more nuclear reactors reach the end of their operating life, more LLRW will be generated and will have a cumulative effect on disposal capacity. However, disposal capacity of LLRW waste facilities would be evaluated at each of those environmental reviews.

ADP states that decommissioning would be done in compliance with the Waste Acceptance Grouping Identification Plan and process control program, RPP, and Offsite Dose Calculation Manual to manage the classification, processing, packaging, and removal of radioactive waste both reduce radiological waste and reduce dose (ADP 2024a,b).

The Decommissioning GEIS did not consider the impacts of nonradioactive waste generation, handling, and disposal. Based on the information provided above, the NRC has evaluated theimpacts of the generation, handling, and disposal of nonradioactive waste for the CR3.

Nonradioactive waste would be either disposed of at a local landfill, recycled, or reused. The NRC staff also assumes that any hazardous waste would be disposed of appropriately as required by local regulations. ADP identified three local facilities for waste disposal or recycling.

In addition, the Citrus County Landfill accepts construction and industrial wastes (Citrus County 2024). The NRC staff expects that ADP would continue to adhere to applicable local, State, and Federal requirements regarding nonradioactive waste generation, handling, and disposal.

Therefore, the NRC staff does not expect a noticeable impact on local landfill capacity from the decommissioning of the CR3. The proposed action would not significantly impact waste management handling at the CR3.

3-53 3.14 Cumulative Impacts The Council on Environmental Quality regulations that implement NEPA define cumulative effects as effects on the environment that result from the incremental effects of the action when added to the effects of other past, present, and reasonably foreseeable actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative effects can result from individually minor but collectively significant actions taking place over a period of time. (40 CFR 1508.1). The NRC staff evaluated whether cumulative environmental effects could result from the incremental effects of the proposed action when added to the effects of other past, present, or reasonably foreseeable actions in the area.

Decommissioning and demolition activities at CR3 have been ongoing since 2020 when the site transitioned from SAFSTOR to DECON status. Current and reasonably foreseeable future actions in the NRC-licensed area include continued operation of the CR3 ISFSI and the CREC.

After CR3 decommissioning is complete, most visible structures (e.g., auxiliary buildings, the containment structure, etc.) would have been demolished and removed. The exception is the ISFSI, which will remain in operation onsite in accordance with ADPs 10 CFR Part 72 general license associated with its 10 CFR Part 50 license. The onsite ISFSI is a passive facility that does not have any moving parts and requires minimum maintenance or management.

Operation of the ISFSI includes minimal security and basic utility services that are already present. Doses to the public and workers are expected to remain within regulatory limits.

Although the ISFSI will remain in place, it would have a minimal impact on visual and scenic resources due its location within the CREC and out of line of sight from the public. Therefore, the NRC staff concludes that CR3 decommissioning activities and the remaining onsite ISFSI would have a minor incremental contribution to cumulative impacts on visual and scenic resources when added to past, present, or reasonably foreseeable future actions.

ADP intends to continue site characterization in phases for the area within in NRC-licensed boundary, but outside of the CR3 site, that contains two coal-fueled units, two large cooling towers, parking lots, coal delivery and storage areas, ash storage area, office buildings, warehouses, barge handling docks, and a railroad (ADP 2024a). ADP anticipates submitting to NRC additional requests to remove portions of land from the licensed boundary in phases but ultimately plans to request the release of the portion of the 358-ha (884-ac) site that is under the 10 CFR Part 50 license, excluding the ISFSI and associated land, for unrestricted use at license termination (ADP 2024a). ADP will also continue groundwater monitoring activities until NRC license requirements are met. Continuation of site characterization and groundwater monitoring require the transportation and onsite presence of a small number of workers that are already present. Surface soil characterization may disturb the top 0.15 m (6 in) of the ground surface but would be in areas that were previously disturbed and would not create a noticeable change in noise, visual impacts, or fugitive dust in addition to CR3 decommissioning activities. The NRC staff concludes that continuation of site characterization and groundwater monitoring activities of areas within in NRC-licensed boundary but outside of the CR3 site would have a minor incremental contribution to cumulative impacts on transportation, noise, visual impacts, or fugitive dust when added to past, present, or reasonably foreseeable future actions.

The NRC-licensed boundary contains two operating coal-fueled power generation units that began operating in the early 1980s and are planned to continue operation after the CR3 decommissioning is complete. Approximately 0.8 km (0.5 mi) east of the NRC-licensed boundary are two natural gas combined cycle units that began operating in 2018. The FDEP permits these units (FDEP 2015). Past, present, and future fossil-fueled power generating activities from these units have and will continue to have negative environmental effects.

Because both of these projects are a larger footprint that the CR3 site and because of the

3-54 environmental impacts of fossil-fuel power generation, NRC staff expects that the environmental impacts from constructing and operating these units are greater than that of the CR3 decommissioning activities.

In March 2023, demolition of the Crystal River Mall, which is approximately 10.5 km (6.5 mi) away from CR3 on US 19 and generally south of the CREC, started and should be completed in 2024 (ADP 2024b). The Crystal River Mall is an approximate 15.8-ha (39-ac) property (Spectrum News 2023). In addition, dozens of transportation projects are ongoing or have been completed in the past few years in Citrus County (FDOT 2024). Transportation of workers and materials to and from the CR3 site may be minimally affected from the demolition of the Crystal River Mall and if road improvement projects overlap with daytime vehicle traffic related to decommissioning activities. Because the individual footprint of these projects is larger than that of the CR3 site, the NRC staff expects that that the environmental impacts from these projects are greater than that of the CR3 decommissioning activities.

If approved, the proposed action would result in the CR3 site soils and structures being demolished, decontaminated, and transported away from the site using NRC regulatory standards that are protective of human health and the environment; thus, over the long term, there would be an overall beneficial effect. As described above, the NRC staff expects that ongoing site characterization within the NRC-licensed boundary would have a minor incremental contribution to cumulative impacts, but that the environmental impacts from the fossil-fueled units, demolition of the Crystal River Mall, and road improvement projects in Citrus County (i.e., over 182 ha (450 ac of construction related projects) could have cumulative environmental effects. Based on the large scale of the fossil-fueled units, demolition of the Crystal River Mall, and road improvement projects in Citrus County, NRC staff expects that cumulative environmental effects from the CR3 decommissioning activities would have a small incremental contribution to cumulative impacts when added to past, present, or reasonably foreseeable future actions. Given that, the NRC staff has concluded that there would be no significant cumulative effects from the proposed action.

3.15 Summary of Environmental Consequences Table 3-10 contains the impacts to those resource areas not addressed generically in the GEIS, and those resource areas that were found to be outside of the bounds of the discussion in the GEIS.

Table 3-10 Summary of Environmental Consequences Specifically Identified in the Decommissioning GEIS Environmental Resource Impacts Considerations Threatened and Endangered Species Decommissioning and license termination activities may affect but are not likely to adversely affect federally listed threatened and endangered species.

Environmental Justice The NRC staff do not expect disproportionate and adverse human health and environmental effects on minority or low-income populations living near CR3.

Offsite Land Use There are no planned activities outside of the operational area, and ADP commits to use BMPs to protect adjoining offsite lands. Therefore, the impact on offsite land use is expected to be SMALL Historic and Cultural Resources beyond operational area There are no planned activities outside of the operational area; therefore, the impact on historical and culture resources beyond the operational area is expected to be SMALL

3-55 Environmental Resource Impacts Considerations Aquatic and Terrestrial Ecology Beyond Operational Area There are no planned activities outside of the operational area. ADP commits to obtaining all necessary licenses from Federal or State agencies and to implementing BMPs to limit or prevent offsite ecological impacts. Therefore, the impact to ecological resources beyond the operational area is expected to be SMALL Waste Management The estimated amount of LLRW to be generated is larger than anticipated in the GEIS, however, it is a small fraction of the total capacity of the WCS waste disposal site. The NRC staff does not expect the non-radioactive waste will be a meaningful amount for the local landfills available for disposal.

Therefore, the impacts of waste generation and management is expected to be SMALL

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CONSULTATION AND COORDINATION 4.1 State Review The NRC provided the draft EA in May 2024 to the Florida Department of Health, Bureau of Environmental Public Health for their review and comment (NRC 2024a). The Florida Department of Health responded on June 7, 2024, with no comments on the draft EA (Florida Department of Health, 2024).

4.2 National Historic Preservation Act Section 106 Consultation NRC staff conducted NHPA consultation pursuant to 36 CFR 800.8(c). The NRC staff contacted four federally recognized Indian Tribes with historic and ancestral ties to the project vicinity to ensure that they were afforded the opportunity to identify their concerns, provide advice on the identification and evaluation of historic properties, including those of traditional religious, and cultural importance, and, if necessary, participate in the resolution of any adverse effects to such properties (NRC 2024b). The four Tribes were (1) Seminole Tribe of Florida, (2) Seminole Nation of Oklahoma, (3) Muscogee Nation, and (4) Miccosukee Tribe of Florida. The Seminole Tribe of Florida responded on April 24, 2024, indicating...no objections or other comments at this time (Seminole Tribe of Florida 2024). The NRC staff did not receive a response from the other Indian Tribes it contacted. The NRC staff also consulted with the Florida SHPO and informed the ACHP (NRC 2024c,d).

As a result of Section 106 compliance activities and consultation, the NRC staff has made a determination of No Historic Properties Affected. The NRC staff solicited comments from the public on the historic and cultural resources sections of the draft EA and findings. Staff published the draft sections on the NRC website and electronically notified the four federally recognized Indian Tribes, the Florida SHPO, and members of the public who have indicated their interest in the CR3. No members of the public commented on the historic and cultural resources sections of the draft EA and findings. The Florida SHPO responded on May 20, 2024, with its concurrence with NRC staffs determination (Florida SHPO 2024). The ACHP responded on May 20, 2024, confirming receipt of NRCs notification pursuant to 36 CFR 800.8(c) (ACHP 2024).

4.3 Endangered Species Act Section 7 Consultation Federal agencies may fulfill their obligations to consult with the FWS under ESA Section 7 in conjunction with the interagency cooperation procedures required by other statutes, including NEPA (50 CFR 402.06(a)). In such cases, the Federal agency should include the results of the ESA Section 7 consultation in the NEPA document (50 CFR 402.06(b)). The NRC considers this EA and associated correspondence with the FWS (FWS 2024b) to fulfill its obligations under ESA Section 7.

Upon receipt of ADPs application, the NRC staff considered whether any federally listed or proposed species or designated or proposed critical habitats may be present in the action area (as defined at 50 CFR 402.02) for the proposed action. As discussed in section 3.8 of this EA, the NRC staff finds that the proposed action may affect, but is not likely to adversely affect the whooping crane (Grus americana), eastern indigo snake (Drymarchon couperi), Everglade snail kite (Rostrhamus sociabilis plumbeus), red-cockaded woodpecker (Picoides borealis), eastern black rail (Laterallus jamaicensis), Florida scrub-jay (Aphelocoma coerulescens), wood stork

4-2 (Mycteria americana), monarch butterfly (Danaus plexippus), and American alligator (Alligator mississippiensis).

The NRC staff transmitted a letter detailing the NRC determinations to the FWS for its review and concurrence on February 29, 2024 (NRC 2024e). On July 8, 2024, the FWS concurred with the NRC determinations (FWS 2024b). The NRC staff incorporates by reference the FWS concurrence letter, discussed in the previous sentence, as well as the exchanges between NRC and FWS during the consultation as part of the staffs basis for its determinations in this document (NRC 2024f,g).

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CONCLUSIONS AND RECOMMENDATIONS The NRC staff prepared this EA as part of its review of the ADP license amendment request to approve its LTP for the CR3 in Citrus County, Florida. If approved, this license amendment request also would add a license condition to the CR3 license reflecting NRCs approval of the LTP and establishing criteria for determining when changes to the LTP require prior NRC approval. The Decommissioning GEIS generically addressed many of the potential environmental impacts of decommissioning at the CR3. During its review of the ADP LTP, the NRC staff concluded that the impacts for most resource areasonsite land use; water resources; air quality; ecology, not including threatened and endangered species or outside the operational area; socioeconomics; historic and cultural resources within the operational area; aesthetics; noise; and transportationwere still bounded by the Decommissioning GEIS.

Therefore, the NRC staff does not expect impacts associated with these issues beyond those discussed in the Decommissioning GEIS, which concluded that the impact level for these issues was SMALL.

Although the GEIS did evaluate radioactive waste management, the NRC staff determined that the GEIS had underestimated the volume of LLRW that the CR3 would produce. Consequently, the NRC staff determined the effects of the proposed action of radioactive waste management for the CR3 on a site-specific basis.

In the GEIS, the NRC staff concluded that it could not necessarily determine the environmental impacts of decommissioning generically for six environmental resource areas. The GEIS concluded that two of these six resource areas (i.e., threatened and endangered species and environmental justice) must always be evaluated on a site-specific basis in site-specific EAs, such as this EA for the CR3 LTP. Depending on site-specific circumstances, the following four additional resource areas are considered to be conditionally site specific: (1) offsite land use, (2) historic and cultural resources beyond the operational area with no current cultural and historic resource survey, (3) terrestrial ecology beyond the operational area, and (4) aquatic ecology beyond the operational area (NRC 2002a).

The NRC staff evaluated the potential environmental impacts of the remaining decommissioning and license termination activities on the following environmental resource areas that cannot be determined generically:

• threatened and endangered species

• environmental justice

• offsite land use

• historic and cultural resources

• terrestrial ecology beyond the operational area

• aquatic ecology beyond the operational area The NRC staff did not identify any significant impacts for any of these resource areas. In addition, topics not included in the GEIS that the NRC staff evaluated in this EA include the affected environment, climate change, cumulative impacts, and nonradioactive waste management.

5-2 On the basis of the findings discussed in this EA, the NRC staff has concluded that there are no significant environmental impacts and a Finding of No Significant Impact is appropriate. That finding will be published in the Federal Register.

6-1 6

LIST OF PREPARERS This EA was prepared by the Environmental Center of Expertise in the Division of Rulemaking, Environmental, and Financial Support in the Office of Nuclear Material Safety and Safeguards.

Contributors to the EA are listed below.

Table 6-1 List of Prepares Contributor Years of Experience, Education Marla Morales

• BA Geology

• MS Geology

• Licenses-Professional Geoscientist - States of Virginia and Texas

• Shipley Group NEPA Certificate

• 23 years of geologic and environmental site analysis, and evaluations Amy Minor

• BA Environmental Studies

• Duke NEPA Certificates

• 23 years of environmental site analysis and evaluations Stacey Imboden

• BS Meteorology

• MS Environmental Engineering

• Duke NEPA Certificate

• 23 years of professional experience Beau Goldstein

• BA Anthropology

• MA Anthropology

• Register of Professional Archaeologists, #15107

• 25 years of professional experience Mitchell Dehmer

• BS Biology

• PSM Environmental Science

• Graduate Certificates - Energy Policy, Environmental Management

• 5 of years professional experience Briana Arlene

• BS Conservation Biology

• MCert Environmental Policy

• 18 years of experience in ecological impact analysis, Endangered Species Act Section 7 consultations, and Essential Fish Habitat consultations Isaac Johnston

• BS Marine Science

• PhD Environmental Engineering and Earth Sciences

• 2 years of professional experience

7-1 7

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