ML25041A178
| ML25041A178 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/10/2025 |
| From: | Reid B ADP CR3 |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25041A177 | List: |
| References | |
| 3F0225-01 | |
| Download: ML25041A178 (1) | |
Text
ADP CR3, LLC CR3 Decommissioning 15760 West Power Line Street l Crystal River, FL 34428 Page 1 of 2 Billy Reid, Site Executive Cellphone: 865-384-6789 Email: breid@northstar.com 10 CFR 50.90 10 CFR 50.83(a) 3F0225-01 February 10, 2025 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Crystal River 3 - License Amendment Request to Remove Property from the Facility Operating License Associated with Partial Site Releases, Proposed Change 262.
Docket Nos. 50-302, 72-1035, and Operating License No. DPR-72 Reference 1: NRC Letter to Duke Energy Florida, LLC, "Crystal River Unit 3 Nuclear Generating Plant - Approval of Partial Site Release for Facility Operating License No. DPR-72", dated January 2, 2020 (ML19339G509).
Dear Sir or Madam:
By letter dated January 2, 2020 (Reference 1), the NRC approved the release of 3,854 acres of the site, classified as radiologically non-impacted, from the Part 50 license for unrestricted use in accordance with 10 CFR 50.83.
In accordance with 10 CFR 50.83, ADP CR3, LLC (ADP CR3) hereby requests approval to remove an additional 618 acres of the site, classified as radiologically non-impacted and MARSSIM Class 3, from the Part 50 License for unrestricted use.
Pursuant to 10 CFR 50.90, ADP CR3 hereby provides this License Amendment Request (LAR) to remove property associated with both Partial Site Releases from the Crystal River Unit 3 (CR3) Operating License. The basis of this request is to return the property to the Duke Energy Crystal River Energy Complex for unrestricted use. provides a description and evaluation of the proposed changes that include the no significant hazards consideration determination and environmental consideration associated with this LAR. Enclosure 2 contains the proposed markup of the wording change to the Operating License Technical Specifications. Enclosure 3 contains the retyped Operating License Technical Specifications., "Crystal River Unit 3 Supporting Information for Request for 2nd Partial Site Release," provides the supporting information for a partial release of the site for unrestricted use before receiving approval of the License Termination Plan (LTP) in accordance with the provisions of 10 CFR 50.83. Attachment 1 includes a description of the property and evaluation of the effect of releasing this property from the CR3 Part 50 license. The revised site description contained in Attachment 1 will be used to update the Defueled Safety Analysis 191
Page 2 of 2 Report once this request is approved.
ADP CR3 is submitting the additional technical documents and reports to support the review of this Partial Site Release request:
CR3 Non-impacted Areas Partial Site Release Phase II Report CR3 R16Y Area Partial Site Release Phase II Report CR3 CASA Area Partial Site Release Phase II Report CR3 SeaLand Area Partial Site Release Phase II Report Historical Site Assessment for Crystal River 3 Crystal River Unit 3 - Partial Site Release Request (ML19022A076)
TSD - Groundwater Well and Withdrawal Permit Limits Under the Florida Department of Environmental Protection Regulations TBD - Basis for No Contaminated Water Dose at CR3 0 CR3 Site Characterization Survey Report (CHAR-01) Impacted Open Land Survey Areas 1 CHAR-06 CR3 Non-impacted Open Land Survey Areas In accordance with 10 CFR 50.91(b), ADP CR3 is providing a copy of this submittal to the State of Florida.
This letter contains no new regulatory commitments.
Should you have any questions concerning this submittal, please contact Mr. John T. Jernigan at (352) 342-0792.
I state under penalty of perjury that the foregoing is true and correct. Executed on February 10, 2025.
Sincerely, Billy Reid Nuclear Executive Cc: Regional Administrator, Region 1 NMSS Project Manager State of Florida 191
ENCLOSURE 1 Crystal River Unit 3 Nuclear Generating Plant Docket Nos. 50-302 / 72-1035 Operating License DPR-72 Proposed Change 262 Description and Evaluation of the Proposed Changes Begins On Next Page 3F0225-01 / Enclosure 1 191
License Amendment Request, Change No. 262, Amend Facility Operating License Technical Specifications Discussion of Change, Regulatory Evaluation, No Significant Hazards Consideration Determination, and Environmental Consideration
1.0 DESCRIPTION
Crystal River Nuclear Power Station (CR3) is currently undergoing active decommissioning and spent fuel has been transferred to the onsite CR3 Independent Spent Fuel Storage Installation (ISFSI). The NRC previously approved a Partial Site Release of 3854 acres from the CR3 Part 50 License by NRC Letter to Duke Energy Florida, "Crystal River Unit 3 Nuclear Generating Plant - Approval of Partial Site Release for Facility Operating License No. DPR-72", dated January 2, 2020 (ML19339G509). In addition, ADP CR3 is requesting to release an additional 618 acres from the CR3 part 50 License by providing this request for a second Partial Site Release in accordance with 10 CFR 50.83. As a result, ADP CR3 proposes to amend Facility Operating License DPR-72, for CR3, to remove the prior approved 3854 acres as well as this additional 618 acres, upon approval, with this Partial Site Release from the associated Technical Specifications Site description. The removal of the 4,400 foot minimum exclusion radius centered on the Reactor Building is no longer applicable as the site has released property via the previous Partial Site Release. The requirement for an abundant supply of cooling water no longer applies to CR3 due to decommissioning activities removing all plant systems utilizing cooling water.
2.0 PROPOSED CHANGE
ADP CR3 proposes to amend the Technical Specifications Site description of the property released by Partial Site Releases and to remove language no longer applicable due to decommissioning activities.
Specifically, CR3 proposes to modify the text to the Operating License Technical Specifications as follows:
4.0 DESIGN FEATURES 4.1 Site The 4,738265 acre site is characterized by a 4,400 foot minimum exclusion radius centered on the Reactor Building; isolation from nearby population centers; sound foundation for structures; an abundant supply of cooling water; an ample supply of power; and favorable conditions of hydrology, geology, seismology, and meteorology.
3.0 REGULATORY EVALUATION
3.1 Applicable Regulatory Requirements 3.1.1 10 CFR 50.83, Release of part of a power reactor facility or site for unrestricted use.
10 CFR 50.83(a)(1), Evaluate the effect of releasing the property to ensure that:
(i)
The dose to individual members of the public does not exceed the limits and standards of 10 CFR Part 20, Subpart D; 3F0225-01 / Enclosure 1 / Page 1 of 4 191
(ii)
There is no reduction in the effectiveness of emergency planning or physical security; (iii)
Effluent releases remain within license conditions; (iv)
The environmental monitoring program and offsite dose calculation manual are revised to account for the changes; (v)
The siting criteria of 10 CFR Part 100 continue to be met; and (vi)
All other applicable statutory and requirements continue to be met.
10 CFR 50.83(a)(2), Perform a historical site assessment of the part of the facility or site to be released; and 10 CFR 50.83(a)(3), Perform surveys adequate to demonstrate compliance with the radiological criteria for unrestricted use specified in 10 CFR 20.1402 for impacted areas.
10 CFR 50.83(b)(1), The results of the evaluations performed in accordance with paragraphs (a)(1) and (a)(2) of this section; 10 CFR 50.83(b)(2), A description of the part of the facility or site to be released; 10 CFR 50.83(b)(3), The schedule for release of the property; 10 CFR 50.83(d)(1), The information specified in paragraphs (b)(1) through (b)(3) of this section; 10 CFR 50.83(d)(2), The methods used for and results obtained from the radiation surveys required to demonstrate compliance with the radiological criteria for unrestricted use specified in 10 CFR 20.1402; and 10 CFR 50.83(d)(3), A supplement to the environmental report, under § 51.53, describing any new information or significant environmental change associated with the licensee's proposed release of the property.
Discussions regarding compliance to these regulations are provided in Attachment 1 of this submittal.
3.1.2 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit.
10 CFR 50.90 states "Whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, as specified in
§50.4 fully describing the changes desired, and following as far as applicable, the form prescribed for original applications." An amendment is requested to remove property via Partial Site Releases and to remove language that no longer applies from the Facility Operating License Technical Specifications.
3.1.3 10 CFR 50.51, Continuation of License 10 CFR 50.51(b) states "Each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the Commission notifies the licensee in writing that the license is terminated. During such period of continued effectiveness the licensee shall:
(1) Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility, including, where applicable, the storage, control and maintenance of the spent fuel, in a safe condition, and 3F0225-01 / Enclosure 1 / Page 2 of 4 191
(2) Conduct activities in accordance with all other restrictions applicable to the facility in accordance with the NRC regulations and the provisions of the specific 10 CFR Part 50 license for the facility."
3.2 No Significant Hazards Consideration Determination ADP CR3 has reviewed the proposed license amendment against each of the criteria in 10 CFR 50.92, Issuance of Amendment, and has concluded that the amendment request does not involve a significant hazards consideration. The following provides ADP CR3's analysis of the issue of no significant hazards consideration:
3.2.1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
No.
The change to the Part 50 License Technical Specifications, specifically Section 4.0 Design Features, to unconditionally release 3854 acres from the Part 50 License was approved prior.
Additionally, the current request to remove an additional 618 acres has been evaluated against the criteria specified in 10 CFR 50.83 to ensure CR3 will continue to comply with all applicable statutory and regulatory requirements that may be affected by the release of the subject property.
This change does not affect possible initiating events for the decommissioning accidents previously evaluated in the CR3 Defueled Safety Analysis Report (DSAR), as updated, or alter the configuration or operation of the facility. Safety limits, limiting safety system settings, and limiting control systems are no longer applicable to CR3 in the permanently defueled mode, and are therefore not relevant.
The proposed change does not affect the parameters used to evaluate compliance with liquid or gaseous effluent limits and has no impact on plant shutdown operations. Therefore, the proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
3.2.2. Does the proposed license amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
No.
The safety analysis for the facility remains accurate as described in the CR3 DSAR, as updated. CR3 continues with decommissioning activities; however, these activities are performed in accordance with approved CR3 work packages/steps and undergo 10 CFR 50.59 screening prior to initiation.
The proposed amendment removes property from the Facility Operating License Technical Specifications for unrestricted use and does not bring about physical changes to the facility.
Therefore, the facility conditions for which the postulated accidents have been evaluated are still valid and no new accident scenarios, failure mechanisms, or single failures are introduced by this amendment. The system operating procedures are not affected. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
3F0225-01 / Enclosure 1 / Page 3 of 4 191
3.2.3. Does the proposed license amendment involve a significant reduction in the margin of safety?
No.
There are no changes to the design or operation of the facility resulting from this amendment.
The proposed change does not affect the parameters used to evaluate compliance with liquid or gaseous effluent limits and has no impact on plant shutdown operations. Accordingly, the postulated accident assumptions in the DSAR, as updated, are not affected. Therefore, the proposed change does not involve a significant reduction in the margin of safety.
3.3 Conclusion Based on the evaluations provided: (1) there is reasonable assurance that the health and safety of the public will not be endangered by the conduct of activities in the proposed manner, and (2) such activities will be conducted in compliance with the NRC's regulations, and (3) the proposed amendment will not be inimical to the common defense and security or the health and safety of the public.
All current survey units have met the indistinguishable from background test as described and performed in the first PSR, as well as demonstrating groundwater is not a viable resource. Additionally, ADP CR3 has demonstrated that if groundwater was a viable resource, the relative dose from groundwater pathways is insignificant.
3.4 Environmental Consideration By NRC Letter to ADP CR3, "Environmental Assessment and Finding of No Significant Impact", dated July 12, 2024 (ML24176A222), the NRC staff issued a finding of no significant impact (FONSI) and an accompanying environmental assessment (EA)
(ML24081A068), concluding there were no significant impacts to the environmental resources associated with the activities to terminate the CR3 Part 50 License. The release of property with this Phase II Partial Site Release is consistent with the release of property associated with terminating the License. As such, the Environmental Assessment that has been performed for the prior submitted License Termination Plan can be applied to the activities for this Partial Site Release and License Amendment Request.
3F0225-01 / Enclosure 1 / Page 4 of 4 191
ENCLOSURE 2 Crystal River Unit 3 Nuclear Generating Plant Docket Nos. 50-302 / 72-1035 Operating License DPR-72 Proposed Change 262 Markup of the Existing Operating License Begins On Next Page 3F0225-01 / Enclosure 2 / Page 1 of 1 191
Design Features 4.0 Crystal River Unit 3 4.0-1 Amendment No. 255262 4.0 DESIGN FEATURES 4.1 Site The 4,738265 acre site is characterized by a 4,400 foot minimum exclusion radius centered on the Reactor Building; isolation from nearby population centers; sound foundation for structures; an abundant supply of cooling water; an ample supply of power; and favorable conditions of hydrology, geology, seismology, and meteorology.
4.2 Not Used 4.3 Fuel Storage Spent fuel shall not be stored in the spent fuel pool.
3F0225-01 / Enclosure 2 / Page 1 of 1
ENCLOSURE 3 Crystal River Unit 3 Nuclear Generating Plant Docket Nos. 50-302 / 72-1035 Operating License DPR-72 Proposed Change 262 Retyped Operating License Begins On Next Page 3F0225-01 / Enclosure 3 / Page 1 of 1 191
4.0 DESIGN FEATURES 4.1 Site The 265 acre site is characterized by isolation from nearby population centers; sound foundation for structures; an ample supply of power; and favorable conditions of hydrology, geology, seismology, and meteorology.
4.2 Not Used 4.3 Fuel Storage Spent fuel shall not be stored in the spent fuel pool.
3F0225-01 / Enclosure 3 / Page 1 of 1