ML24226B239

Application for License Amendment Request to Add License Condition to Include License Termination Plan Requirements – Acknowledgement of Withdrawal

ML24226B239
Person / Time
Site:	Crystal River
Issue date:	08/27/2024
From:	William Allen Reactor Decommissioning Branch
To:	Reid B ADP CR3
References
EPID L-2022-LLA-0194
Download: ML24226B239 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Billy Reid, Site Executive ADP CR3, LLC 157060 West Power Line Street Crystal River, FL 34428

SUBJECT:

APPLICATION FOR LICENSE AMENDMENT REQUEST TO ADD LICENSE CONDITION TO INCLUDE LICENSE TERMINATION PLAN REQUIREMENTS -

ACKNOWLEDGEMENT OF WITHDRAWAL (EPID L-2022-LLA-0194)

Dear Billy Reid:

By letter dated December 12, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22355A441), as supplemented by letter dated June 9, 2023 (ML23163A063), Accelerated Decommissioning Partners Crystal River Unit 3, LLC (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) to approve a request to add a condition to include License Termination Plan (LTP) requirements to the NRC license, No.

DPR-72, for Crystal River Unit 3 Nuclear Generating Plant (CR3). The NRC staff issued a request for additional information on December 22, 2023 (ML23354A057). On March 29, 2024 (ML24093A153), as supplemented on July 23, 2024 (ML24205A158), the licensee responded to the additional information request.

The NRC staff found the additional information insufficient to complete its review. A list of the information insufficiencies is provided in the Enclosure to this letter. Consequently, by letter dated August 12, 2024 (ML24225A207), you requested to withdraw the application from NRC review. The NRC acknowledges your request to withdraw the application. NRC staff activities on the review have ceased and the associated Enterprise Project Identifier number has been closed.

The NRC encourages you to engage with the staff before you resubmit the LTP application either through pre-application meetings or through a readiness assessment. A readiness assessment of your LTP resubmittal will allow the NRC staff to understand the level of detail in the draft application as well as to identify any major issues or information gaps between the draft application and the required technical content. A readiness assessment is not part of the NRCs official acceptance review process. Therefore, the readiness assessment observations provided will not predetermine whether the application will be docketed. More information on readiness assessments can be found in NRC Office Instruction LIC-116, Preapplication Readiness Assessment (ML20104B698).August 27, 2024 B. Reid 2 In accordance with 10 CFR Part 2, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. If you have any questions regarding this matter, please contact me by telephone at (301) 415-6877 or via email at william.allen@nrc.gov.

Sincerely, Chris Allen, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-302 License No. DPR-72 EPID No. L-2022-LLA-0194

Enclosure:

Information Insufficiencies cc: Crystal River Listserv Signed by Allen, William on 08/27/24

INFORMATION INSUFFICIENCIES

NRC staff identified the following information insufficiencies in the LTP, which precluded the NRC staff from being able to reach a conclusion that (1) there is reasonable assurance that the health and safety of the public will not be endangered by implementation of the LTP as proposed, (2) there is reasonable assurance that the activities proposed will be conducted in compliance with the Commissions regulations, or (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

A) ADP CR3 did not ensure that all technical basis documents referenced in the LTP employed reasonable and established scientific methods. For example, survey Technical Basis Documents should assure that (1) measurements referenced in the documents are performed using calibrated instrumentation, with measurement uncertainty and detection limits specified (e.g., measurements of soil moisture levels in samples), and (2) statistical comparisons to established and regulatorily accepted methods are conducted (e.g., statistical comparison of in-situ gross gamma measurements to soil sample analyses). NRC staff recommends that novel survey methods, if proposed, be submitted to the NRC or otherwise communicated for regulatory review prior to the LTP resubmittal to avoid adverse schedule impacts and to ensure a timely LTP review.

B) The As Low As Reasonably Achievable (ALARA) analysis did not separately address each radionuclide of concern (ROC) identified in the Final Status Survey (FSS) Plans using the radionuclide specific half-life and derived concentration guideline level (DCGL) for each option evaluated in the ALARA analysis.

C) Determination of the ROCs and insignificant contributors did not incorporate site characterization data, as expected when a statistically significant number of representative samples were used to make these determinations, as well as to delineate how differing values or radionuclides were considered.

D) The FSS Plans did not incorporate limits for elevated residual radioactivity concentrations or provide commitments that no residual radioactivity concentrations greater than the DCGL will remain. Most complex sites have had areas of elevated residual radioactivity that had to be considered using elevated measurement criteria.

E) The FSS Plans were not fully developed for all potentially contaminated media to remain onsite in a defined end state.

F) The FSS Plan for embedded and buried pipe did not include ongoing sampling to verify ROCs and surrogate ratios.

G) Inadequate justification was provided to demonstrate that use of groundwater across the site is not reasonable for the foreseeable future. Nor was the alternative of the use and ingestion of groundwater incorporated as a potential pathway of exposure to an average member of the critical group.

H) The basis for the DCGLs provided for subsurface structures did not address all reasonable potential exposures (e.g., for site workers or residents who may excavate and handle the material) or address why those pathways were not applicable for the site.

Enclosure I) FSS Plans did not incorporate an appropriate level of verification of the ROCs, insignificant contributors, and surrogate ratios during FSS. Remediation may alter site conditions and radionuclide ratios upon which these determinations are made.

See the last paragraph of Section 4.5.3.5 in draft MARSSIM, Rev. 2 (ML21008A572).

J) The LTP had numerous document quality issues as recognized by the licensee.

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ML24226B239 OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB R-I/EAGLT NMSS/DUWP/RTAB NAME JParrott JPWAllen WA NWarnek NW CMcKenney CM DATE Aug 19, 2024 Aug 16, 2024 Aug 27, 2024 Aug 20, 2024 OFFICE NMSS/DUWP/RDB NAME WAllen WA DATE Aug 27, 2024