ML25041A179
| ML25041A179 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/10/2025 |
| From: | ADP CR3 |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25041A177 | List: |
| References | |
| 3F0225-01 | |
| Download: ML25041A179 (1) | |
Text
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 ADP CR3, LLC DOCKET NUMBER 50-302 / DOCKET NUMBER 72-1035 LICENSE NUMBER DPR - 72 ATTACHMENT 1 CRYSTAL RIVER UNIT 3 SUPPORTING INFORMATION FOR REQUEST FOR 2nd PARTIAL SITE RELEASE December 2024 3F0225-01 / Attachment 1
ADP CR3, LLC CR3 Decommissioning 15760 West Power Line Street l Crystal River, FL 34428 3F0225-01 / Attachment 1 / Page 1 of 36
ADP CR3, LLC CR3 Decommissioning 15760 West Power Line Street l Crystal River, FL 34428 PURPOSE Accelerated Decommissioning Partners Crystal River Unit 3, LLC, (ADP-CR3) is requesting the release of remaining portions of the non-impacted areas of the current Controlled Area, also referred to as the 884-acre Site at the Crystal River Energy Complex (CREC). Specifically, ADP CR3 requests NRC approval for release of 618 acres per 10 CFR 50.83, Release of Part of a Power Reactor Facility or Site for Unrestricted Use, (CFR, 2024a) from the jurisdiction of Crystal River Unit 3 Nuclear Generating Plant (CR3) NRC operating license DPR-72. This is the second Partial Site Release (PSR) for this facility.
This request considers about 70.9 acres which were conservatively deemed Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) Class 3 areas and are now identified as indistinguishable from background, and an additional 548 acres which were considered as non-impacted (NIA) by the Historical Site Assessment (HSA) (RSCS, 2016). The areas considered as NIA and Class 3 have each been subjected to a Final Status Survey (FSS) and results are provided herein.
The purpose of this document is to provide a summary of the results of radiological surveys performed in support of the Partial Site Release (PSR) at the CREC as well as a summary of the reviews and assessments performed that show that the property is indistinguishable from background radiation levels.
The release of the property will not have any adverse impact on public health or safety or adverse impact on the ability of the site in aggregate to meet 10 CFR Part 20, Subpart D, Radiation Dose Limits for Individual Members of the Public, (CFR, 2024b) and Subpart E, Radiological Criteria for License Termination (CFR, 2024c). Guidance was also followed from NUREG-1757, Volume 2, Revision 2, Consolidated Decommissioning Guidance Characterization, Survey, and Determination of Radiological Criteria - Final Report, (NRC, 2022), and NRC Regulatory Guide 1.179, Revision 2, Standard Format and Contents for License Termination Plans for Nuclear Power Reactors, (NRC, 2019). Appendixes K and L of the NUREG provided guidance for meeting the Subpart E dose limits.
All current survey units have met the indistinguishable from background test as described and performed in the first PSR. Compliance for Subpart E for water dose is discussed in detail with quotations from a Technical Basis Document, Basis for No Contaminated Water Dose at CR3, (ADP-CR3, 2024h). Figure 1 shows the facility location, Figure 2 shows the current Controlled Area Boundary, Figure 3 displays and overview of all the survey areas, Figures 4 through 12 display each specific survey unit discussed in this PSR, Figure 13 shows the new Controlled Area Boundary, and Figure 14 displays the new Thermo-Luminescent Dosimeter (TLD) locations.
3F0225-01 / Attachment 1 / Page 2 of 36
ADP CR3, LLC CR3 Decommissioning 15760 West Power Line Street l Crystal River, FL 34428 BACKGROUND The CR3 site is located at 15760 West Powerline Street, Crystal River, Florida, 34428, with coordinates of latitude 28° 57' 25.87" north and longitude 82° 41' 55.95" west. The site is about 7.5 miles northwest of Crystal River and 70 miles north of Tampa in Citrus County, Florida.
The station is part of the larger Crystal River Energy Center (CREC), which is located on the Gulf of Mexico in Citrus County, Florida. In addition to CR3, other structures on the CREC included two razed fossil-fueled power plants (Units 1 and 2) and existing plants (4 and 5), two large natural draft cooling towers, coal delivery and storage areas, ash storage areas, office buildings, warehouses, barge handling docks, and a railroad. Units 1 and 2 have recently been decommissioned; these areas are not part of this PSR request.
CR3 last produced power in September 2009, while shutting down for Refuel 16. During activities to replace steam generators, a portion of the containment concrete wall became delaminated. While completing repairs, additional delamination occurred. Figure 1 illustrates the project area location.
The footprint of the CR3 site consists of non-impacted 548 acres and the impacted area of about 335 acres including the ISFSI. NorthStar intends to return the non-impacted portion, and three areas considered MARSSIM Class 3 to Duke Energy as soon as possible upon NRC approval as a partial site release. The PSR areas have undergone an environmental assessment including considerable radiological scanning and sampling to support the transfer.
CR3 has also reviewed site history and operations to determine that areas within this request can be released without any limitations or conditions as defined in applicable regulations. The facilitys location is shown Figure 1.
The original license holder was Duke Energy Florida and on October 1, 2020, transferred the NRC license for CR3 to ADP-CR3, LLC (ADP-CR3), a joint venture between NorthStar Group Services and Orano USA. Per the agreement, Duke remains the NRC-licensed owner of the plant, property, and decommissioning trust fund but not the spent fuel. ADP-CR3 became the NRC-licensed operator responsible for decommissioning and ADP-SF1 became the owner of the spent nuclear fuel. A revised Post-Shutdown Decommissioning Activities Report (PSDAR) reflecting the changes from SAFSTOR1 to DECON2 was submitted on June 26, 2019 (CR3, 2019).
1 SAFSTOR is a long-term storage condition for a permanently shut down nuclear power plant. During SAFSTOR, radioactive contamination decreases substantially, making subsequent decontamination and demolition easier and reducing the amount of LLW requiring disposal.
2 DECON is a phase of reactor decommissioning in which structures, systems, and components that contain radioactive contamination are removed from a site and safely disposed of at a commercially operated low-level waste disposal facility or decontaminated to a level that permits the site to be released for unrestricted use.
3F0225-01 / Attachment 1 / Page 3 of 36
ADP CR3, LLC CR3 Decommissioning 15760 West Power Line Street l Crystal River, FL 34428 Figure 1. CR3 Site Location PREVIOUS PSR Enclosed as Attachment 7, on January 22, 2019, CR3 submitted a Partial Site Release (PSR) request with the NRC to reduce the licensed footprint by releasing about 3,854 acres of the non-impacted areas from the approximate 4,738-acre site per 10 Part 50.83, Release of Part of a Power Reactor Facility or Site for Unrestricted Use (ADAMS Accession No. ML19022A076).
As documented in NRC to CR3 letter dated January 2, 2020 (ADAMS Accession No. ML19339G509), the NRC approved the release of the non-impacted areas.
A Principal Study Question (PSQ) of the confirmatory measurement survey for the earlier PSR was: Are radionuclide concentrations in the non-impacted land area consistent with available regional background data and ROC statistical parameters? The acceptable response to the PSQ by the NRC for the work was that background was achieved when Cs-137 results did not exceed 0.132 pCi/g (picocuries per gram) which is the 95th percentile value from background assessment with no other identification of plant related Radionuclides Of Concern (ROCs) greater than Minimum Detectable Activity (MDA) (Duke Energy, 2019). The stated criterion will be applied to this PSR as a 95th percentile value recognizing that higher values occur at the 99th percentile. The previous PSR also discussed how background could have a wide range at CR3 particularly if vegetative matter is a part of the soil matter and cannot be removed from samples.
The previous PSR reduced the current boundary to an approximately 884-acre site, also referred to as the Controlled Area and is defined by the site boundary depicted in Figure 2.
3F0225-01 / Attachment 1 / Page 4 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 2. Current 884-Acre Site Map of Controlled Area 3F0225-01 / Attachment 1 / Page 5 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 DESCRIPTION OF THE PROPERTY The portion of the site under the jurisdiction of 10 CFR Part 50 License is approximately 884 acres in size. Of the 884 acres, ADP-CR3 has decided to release approximately 618 acres under the 10 CFR Part 50 License (see Figure 2). The proposed site boundary/CR3 Controlled Area is comprised of the 265-acre footprint of the CR3 nuclear facility, including industrialized portions of the CREC, primarily comprised of two razed coal plants (Units 1 and 2). The description of the requested release area of 618 acres and the proposed Controlled Area 265 acres property, including the ISFSI, is provided in Attachment 2 to this submittal, CR3 Non-impacted Areas Partial Site Release Phase II Report, (ADP-CR3, 2024a). The scope of the PSR request is the non-impacted areas consisting of 548 acres and three previously designated impacted areas consisting of 70.9 acres of industrialized areas which will be returned to Duke Energy Ownership for CREC use. This proposed acreage for release has been sub-divided from the HSA into six non-impacted and three previously designated Class 3 areas.
The entire site has now been characterized and results for the referenced six NIA areas are summarized in Attachment 11, CHAR-06 CR3 Non-Impacted Open Land Area Survey Areas, (ADP-CR3, 2024c) and the three areas previously classified as MARSSIM Class 3 are also summarized in Attachment 10, CHAR-01 Impacted Open Land Survey Areas, (ADP-CR3, 2024d), in Attachment 3, CR3 R16Y Area Partial Site Release Phase II Report, (ADP-CR3, 2024e), Attachment 4, CR3 CASA Area Partial Site Release Phase II Report, (ADP-CR3, 2024f), and Attachment 5, CR3 SeaLand Area Partial Site Release Phase II Report, (ADP-CR3, 2024g). A listing of all survey areas in the scope of this PSR is provided in Table 1 and an overview is provided in Figure 3.
Table 1. Description of PSR Land Survey Areas Survey Area ID Survey Areas Description Size (acres)
Size (m2)
NIA-01 Northern most section of the Unit 4 & 5 operating plant footprint 98.0 396,780 NIA-02 Southern section of the Unit 4 & 5 operating plant footprint 95.3 385,907 NIA-03 Southern section of the Unit 4 & 5 coal yard and open land area 99.3 402,051 NIA-04 Mid-western section of the Unit 4 & 5 switchyard and open land area 77.9 315,423 NIA-05 Mid-eastern section of the Unit 4 & 5 switchyard and open land area 90.1 364,690 NIA-06 Southern section on the licensed footprint below the intake canal 86.7 351,202 R16Y North Shipping Yard 3.8 15,444 CASA Coal Ash Storage Area 66.4 268,846 SEAL SeaLand Container Storage Area (within NIA-06) 0.7 2,712 Totals 618.2 2,503,055 3F0225-01 / Attachment 1 / Page 6 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 3. Overview of Survey Areas and Non-Impacted Areas 3F0225-01 / Attachment 1 / Page 7 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 4. Overview of Survey Area NIA-01 3F0225-01 / Attachment 1 / Page 8 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 5. Overview of Survey Area NIA-02 3F0225-01 / Attachment 1 / Page 9 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 6. Overview of Survey Area NIA-03 3F0225-01 / Attachment 1 / Page 10 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 7. Overview of Survey Area NIA-04 3F0225-01 / Attachment 1 / Page 11 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 8. Overview of Survey Area NIA-05 3F0225-01 / Attachment 1 / Page 12 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 9. Overview of Survey Area NIA-06 3F0225-01 / Attachment 1 / Page 13 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 10. Overview of Survey Area CASA-01 3F0225-01 / Attachment 1 / Page 14 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 11. Overview of Survey Area SEAL 3F0225-01 / Attachment 1 / Page 15 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 12. Overview of Survey Area R16Y-01 3F0225-01 / Attachment 1 / Page 16 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 METHODOLOGY Because CR3 was licensed as a power reactor, a 10 CFR 50.83 release request will be followed. For this report, the requirements from 10 CFR 50.83 are presented in italics at the beginning of each section, then a description is provided of how that requirement is met. It should be noted that for release of impacted areas per 10 CFR Part 50.83(a) and non-impacted areas per 10 CFR Part 50.83(b), both sections of these respective regulations require evaluations per paragraphs 50.83(a)(1) and (a)(2):
For the 10 CFR 50.83 (a)(1) requirements: 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 (CFR, 2024b).
The reactor in question has permanently ceased operations and is being decommissioned in a DECON3 status.
The radiological surveys performed on this property show that there is no plant-related residual radioactivity on this property above expected background levels. ADP CR3 strictly controls effluents to ensure radioactivity released to the environment is maintained ALARA and does not exceed federal release limit criteria.
Direct-dose measurements at the new boundary have been consistent with background (ADP-CR3 2023 and ADP-CR3 2024a) and thus show member of public dose to be below NRC and EPA limits. For further documentation going forward, additional TLDs, at the locations shown below, will be placed around the remaining Controlled Area. This TLD set will be included in the CR3 Area TLD monitoring program under procedure HPP-333 which is used to assess boundary dose and member of public dose (CR3, 2022b).
3 A phase of reactor decommissioning in which structures, systems, and components that contain radioactive contamination are removed from a site and safely disposed of at a commercially operated low-level waste disposal facility or decontaminated to a level that permits the site to be released for unrestricted use.
3F0225-01 / Attachment 1 / Page 17 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 13. New Controlled Area Boundary 3F0225-01 / Attachment 1 / Page 18 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Figure 14. TLD Locations Along Proposed Site Boundary 3F0225-01 / Attachment 1 / Page 19 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 (ii)
There is no reduction in the effectiveness of emergency planning or physical security.
ADP-CR3 has evaluated the release of this land regarding Emergency Planning and Physical Security, specifically in accordance with10 CFR 50.54(q) and (p). No credit is taken for this land in either the Emergency Plan or Security Plan. Therefore, the release of the subject property has no adverse effect on either plan.
(iii)
Effluent releases remain within license conditions.
Site programs to assess and maintain effluent releases within license conditions remain in effect and the early release of the subject property does not impact those programs. Therefore, the effluent releases from the site will remain within license conditions. The Annual Effluent reports for calendar years 2022 and 2023 reflect the compliance with license conditions and that there are limited air emissions. (ADP-CR3, 2023 and ADP-CR3, 2024b).
(iv)
The environmental monitoring program and offsite dose calculation manual are revised to account for the changes.
Based on a review of the current Radiological Environmental Monitoring Program (REMP) sampling locations and TLD positions, no changes to the REMP program are needed when the Controlled Area is reduced to 265 acres which includes the ISFSI.
Changes to the Offsite Dose Calculation Manual (ODCM) will be required when the new Controlled Area/Site boundary becomes effective to re-define the boundary.
(v)
The siting criteria of 10 CFR Part 100 continue to be met (2024d).
The release of the subject property has been reviewed with respect to the siting criteria in 10 CFR 100 and it has been determined that the requirements of 10 CFR 100 are either not impacted (e.g., 10 CFR 100.11, Determination of exclusion area, low population zone, or population center distance, or 10 CFR 100 Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants) or are not applicable (e.g.,
10 CFR 100, Subpart B, Evaluation Factors for Stationary Power Reactor Site Applications on or After January 10, 1997). ADP-CR3 will continue to control the Controlled Area and maintain the ability to remove members of the public from the Controlled Area in the case of a radiological emergency.
(vi)
All other applicable statutory and regulatory requirements continue to be met.
ADP CR3 maintains policies and procedures to ensure that statutory and regulatory requirements continue to be met. Early release of the subject property has no adverse effect on these policies and procedures.
In summary, the proposed release of the subject property from the 10 CFR Part 50 License will not have any impact on the CR3 facilitys continued compliance with applicable NRC regulatory standards.
3F0225-01 / Attachment 1 / Page 20 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 For the 10 CFR 50.83 (a)(2) requirement: Perform a historical site assessment of the part of the facility or site to be released.
In accordance with the guidance provided in Section 3.0 of NUREG-1575, Multi Agency Radiation Survey and Site Investigation Manual (MARSSIM) (NRC, 2000), a Historical Site Assessment (HSA) was performed and documented in June 2016. The Historical Site Assessment for Crystal River 3, Rev. 0 (RSCS, 2016) is included as Attachment 6 to this submittal. Along with interviews with long-tenured employees, the following historical information was reviewed and compiled for the HSA:
Records from the Florida Department of Environmental Protection (FDEP)
Incident files (ARs, NCORs, PCs, etc.)
Special survey and operational radiological survey records HP and Operator logs Engineering reports of subsurface investigations
- Reports of station inspections by American Nuclear Insurers (ANI)
CR3 file maintained in compliance with 10 CFR 50.75(g) [3], namely HPP0230 CR3 Offsite Dose Calculation Manual (ODCM)
CR3 Final Safety Analysis Report (FSAR)
CR3 Spill Prevention, Control and Countermeasures (SPCC) Plan CR3 Storm Water Pollution Prevention Plan (SWPPP)
CR3 Annual Radioactive Effluent Release Reports CR3 Annual Radiological Environmental Monitoring Reports The HSA was a detailed investigation to collect existing information from the start of CR3s activities related to radioactive materials or other contaminants for the site and its surroundings, including the 618 acres subject to this partial site release. The HSA focused on historical events and routine operational processes that resulted in the contamination of the plant systems, onsite buildings, surface, and subsurface soils within the CR3 Controlled Area as well as support structures, open land areas and subsurface soils outside of the CR3 Controlled Area, but within the Owner Controlled Areas (OCA). The scope of the HSA included potential contamination from radioactive materials, hazardous materials, and state-regulated materials.
The HSA investigation was designed to obtain sufficient information to provide initial classification of the site land areas and structures as impacted or non-impacted. Impacted areas have potential for contamination (based on historical data) or contain known contamination (based on past or preliminary radiological surveillance). The MARSSIM defines non-impacted areas as those areas where there is no reasonable possibility of residual contamination (NRC, 2000).
The HSA included a visual inspection of certain areas, interviews with individuals knowledgeable of operations and radioactive material handling, storage, and disposal (RSCS, 2016). The NIA areas identified in Figure 4-3 were considered non-impacted.
3F0225-01 / Attachment 1 / Page 21 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Also, according to the HSA, during the period between 2013 and 2015, Duke Energy issued questionnaires to departing employees in an effort to obtain process knowledge and understand whether there was any knowledge of events (spills, leaks, etc.) involving radiological or hazardous material in addition to the events that had already been documented. A total of approximately 90 questionnaires were reviewed, none of which identified any additional events.
Several station employees were consulted during the preparation of the HSA regarding information related to their work responsibilities and their recollection of historical contamination events that may have significance during plant decommissioning. A summary of those consulted and the nature of the information discussed is contained in Table 2.
Table 2. CR3 Employee Discussion Subjects Employee Discussion Subjects M. Culver Former site facilities (tents, trailers, etc.), storm water retention ponds M. Siapno Contamination events, primary to secondary side leakage, settling ponds, radioactive waste issues, failed fuel I. Wilson Operational events, general plant knowledge R. Pinner Environmental information (groundwater & effluents)
C. McKeown Operational events G. McCallum Site walkdown discussing status of Structures, Systems, and Components B. Akins Radiation protection program J. Lane Underground pipes, plant configuration C. Burtoff Operating history P. Rose Plant licensing J. Endsley Electrical transformers and circuit breakers T. Hobbs HSA scope, plant licensing issues M. VanSicklen Operational status of selected SSCs A. Riley Document Control Based on the responses to the employee questionnaire, there do not appear to be any undocumented incidents of contamination at the station environs that would be significant for its decommissioning.
Further, ADP-CR3 review of site records indicates that activities with licensed material were mostly limited to approximately 335 acres of the site which is bounded by the NIA land on the North and South sides. No documentation was identified that indicated an impact on the NIA area.
The HSA identified areas outside of the Protected Area as non-impacted because they were not specifically identified in the HSA. These areas include the six open land areas at CR3 as non-impacted shown as NIA in Table 1.
3F0225-01 / Attachment 1 / Page 22 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Details regarding these areas are provided in Attachment 2 to this PSR request, CR3 Non-impacted Open Land Area Survey Areas, (ADP-CR3, 2024c).
NIA northern most section of the Unit 4 & 5 operating plant footprint NIA southern section of the Unit 4 & 5 operating plant footprint NIA southern section of the Unit 4 & 5 coal yard and open land area NIA mid-western section of the Unit 4 & 5 switchyard and open land area NIA mid-eastern section of the Unit 4 & 5 switchyard and open land area NIA southern section on the licensed footprint below the intake canal The HSA provides that if insufficient data are available to confirm a classification of non-impacted, the area is classified conservatively as Class 3 until sufficient characterization data are obtained to support a classification of non-impacted. This is the apparent reason R16 Storage Yard (R16Y), the Unit 4 and 5 Coal Ash Storage Area (CASA), and the SeaLand container storage area (SEAL) were conservatively designated MARSSIM Class 3. However, sufficient surveys and evaluations have since been conducted for them to be designated as indistinguishable from background. Quotes from the HSA are provided to establish how these areas were conservatively assigned as Class 3 areas and that the classification was preliminary.
R16 Storage Yard located between CR3 and Crystal River 4/5 (R16Y)
The R16 Shipping Yard, also referred to as the North Shipping Yard, is located north of CR3, north of the Switch Yard and outside the PA... This area was used as a RAM shipment staging area during Refuel Outage #16. A release survey (RS13- 07-0285) was performed in July, 2013, which consisted of a gamma walkover survey and five (5) soil samples. The soil samples were isotopically analyzed to environmental Lower Levels of Detection (LLDs) and did not identify any plant derived activity. The values were consistent with the values obtained during a baseline survey (RS09-06-0266) conducted in June of 2009, prior to use of the area.
The R16 Shipping Yard is preliminarily classified as a MARSSIM Class 3 area based on the discussion above, and the presumption that if residual radioactivity is present, its concentration will not exceed a small fraction of the acceptance criteria.
Unit 4 and 5 Coal Ash Storage Area (CASA)
Unit 4 and 5 Coal Ash Storage Area is a large coal ash storage area east of Units 4 and 5... Sediment dredged from the Settling Ponds was deposited in a portion of this area.
While licensed material has been identified in Settling Pond sediment, the concentrations have been very low relative to anticipated dose based DCGLs based on a reasonable pathway model.
The Unit 4 and 5 Coal Ash Storage Area is preliminarily classified as a MARSSIM Class 3 area based on the discussion above, and the presumption that if residual radioactivity is present, its concentration will not exceed a small fraction of the acceptance criteria.
3F0225-01 / Attachment 1 / Page 23 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 SeaLand Container Storage Area (SEAL)
This area was used as a SeaLand container storage area during Refuel Outage #16. A release survey (RS10-07-0090) was performed in July, 2010, which consisted of a gamma walkover survey and five (5) soil samples. The soil samples were isotopically analyzed to environmental LLDs and did not identify any plant derived activity. The dose rates in the area were higher, but consistent with background levels, than the values obtained during a baseline survey (RS09-05-0244), conducted in May of 2009, prior to use of the area. Soil samples taken as part of the release survey following use of the area, failed to identify plant derived material when counted to environmental LLDs.
The SeaLand Container Storage Area is preliminarily classified as a MARSSIM Class 3 area based on the discussion above, and the presumption that if residual radioactivity is present, its concentration will not exceed a small fraction of the acceptance criteria.
For the 10 CFR 50.83 (a)(3) requirement: Perform surveys adequate to demonstrate compliance with the radiological criteria for unrestricted use specified in 10 CFR 20.1402 for impacted areas.
Per 10 CFR 20.1402, a site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a TEDE to an average member of the critical group that does not exceed 25 mrem (0.25 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).
In formulating a complete exposure scenario for this proposed PSR, ADP-CR3 considered available information (from the PSR area, the site, and the prior PSR) that could rule out further consideration of specific sources or transport pathways. Although investigation of potential sources and transport pathways can become complicated, ADP-CR3 ruled out potential sources and transport pathways with relatively simple and available information. ADP-CR3 ruled out sources discussed in NUREG-1757 Appendixes K and L which would have required additional exposure scenario evaluations; these issues are further discussed in Attachment 8, Groundwater Well and Withdrawal Permit Limits Under the Florida Department of Environmental Protection Regulations, (H&A, 2024) and Attachment 9, Basis for No Contaminated Water Dose at CR3, (ADP-CR3, 2024h).
Exposure to contaminated soil was ruled out which would provide multiple pathways for a resident farmer, ADP-CR3s average member of the critical group. CR3 has taken the position that if identified radioactivity levels are within natural background ranges with no plant related radionuclides identified, the survey unit meets the requirements of 10 CFR 20.1402, and no other statistical test is required. This is a de facto indistinguishable from background criterion and it will be shown that all survey units meet the criterion, i.e.,
there is no soil contamination and no pathway.
3F0225-01 / Attachment 1 / Page 24 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 The evaluation of the exposure scenarios and pathways of exposure for Crystal River 3 also determined that the groundwater was not usable as a source of drinking water or other waterborne pathways, such as irrigation. This determination was based on several factors, including salinity; the primary factor was that based on State of Florida regulations, a well and groundwater extraction would not be permitted (H&A, 2024).
However, since the elimination of the waterborne pathways was founded, in part, on a regulatory constraint (restriction on permitting a well and extraction), there was concern that this restriction could be changed in the future. The feasibility of any significant changes in the future was proven impossible for the suite of ROCs at CR3 and the relative dose was considered insignificance for groundwater pathways. Evaluations of the waterborne pathways of exposures was performed using the RESRAD-ONSITE code (ADP-CR3, 2024h).
The remaining potential impact on PSR requested areas from the site would be due to airborne releases from the reactor or other site facilities. Any impact from the site airborne releases would have been fairly uniformly dispersed across areas of interest.
The Annual Effluent reports for calendar years 2022 and 2023 reflect the compliance with license conditions and that there are limited air emissions (ADP-CR3, 2023 and ADP-CR3, 2024b).
The first PSR, Attachment 7, provided sufficient technical justification and found acceptable for a Scenario B indistinguishable from background evaluation, as defined in NUREG-1757, Volume 2, Revision 2; that evaluation is sufficient for this PSR as the same release criterion is applied. As a Scenario B type indistinguishable from background evaluation, this section describes major steps performed in the first PSR and remain viable today to demonstrate such when the residual radioactivity is indistinguishable from background:
(1) assess background variability using the Kruskal-Wallis test, (2) determine a concentration of radioactivity that is indistinguishable from background, (3) except for Cs-137, no other plant-related radionuclides were identified.
As indicated, sufficient surveys and evaluations have been performed to identify the R16YArea, the CASA Area, and the SeaLand Area as indistinguishable from background. Data presented from these evaluations in detail below show that of the ROCs only Cs-137 is detectable within the background radiation range and there is no indication of residual contamination within either R16Y, CASA, or SEAL. Site water wells are saline and drinking water is piped in from over 5 miles away; further, there is no contaminated aquifer with radioactive materials from CR3 operations. ALARA has been achieved through the absence of contamination. Any airborne material from the site is minimal and releases are within license conditions.
For the three areas conservatively designated Class 3 in the HSA, a description of them and summary of the FSSs conducted are provided below.
3F0225-01 / Attachment 1 / Page 25 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 R16Y - Open Land Area R16 Shipping Yard Area Survey Unit R16Y is approximately 15,444 m2 or 3.8 acres in size. The area is located north of CR3 and the Switch Yard; it is also referred to as the North Shipping Yard. The area was used as a radioactive material (RAM) shipment staging area during Refuel Outage #16; therefore, it was conservatively classified as MARSSIM Class 3 in the HSA (RSCS, 2016). None of the containers were opened in the area. It is bounded by non-impacted areas on all sides and consists of a single survey unit as shown in Figure 12.
An FSS for R16Y, Attachment 3, was designed and executed using the guidance provided in MARSSIM and NUREG-1757, Volume 2, Revision 2. Both Data Quality Objectives and survey methodology were included in detailed survey packages. These describe the process, organization, functional sample activities, Data Quality Objective process, and measures necessary to conduct surveys in the field. The surveys were carried out via the survey packages described.
The FSS was conducted on October 6-29, 2023. Nineteen surficial soil samples were collected from the Survey Unit R16Y-01 and analyzed for gamma-emitting nuclides by the on-site laboratory using APEX-Gamma spectroscopy. Two samples were randomly selected and submitted to GEL Laboratories, LLC, (GEL) for analysis of hard-to-detect (HTD4) radionuclide analysis. For quality assurance/quality control (QA/QC) purposes, a split and a recount sample were collected/analyzed per survey unit. No quality QA/QC issues were noted that would impact on the overall confidence of the results nor the conclusions of the surveys. Results of the FSS are that no plant related activity other than Cs-137 was identified above MDA values and that Cs-137 levels were within the normal background threshold of 0.132 pCi/g. The survey details are provided in the Attached report, CR3 R16Y Area Partial Site Release Phase II Report, (ADP-CR3, 2024e).
The survey unit is considered indistinguishable from background.
CASA - Open Land Area Unit 4/5 Coal Ash Storage Area The Unit 4/5 Coal Ash Storage Area (CASA) Survey Area is a large coal ash storage area east of Units 4 and 5. It is approximately 268,846 m2 or 66.4 acres and is bounded on all sides by non-impacted areas. The CASA was conservatively classified as a MARSSIM Class 3 area based upon a limited but unknown volume of sediment dredged from the Settling Ponds being deposited in a portion of this area. Per the HSA, The Unit 4 and 5 Coal Ash Storage Area is preliminarily classified as a MARSSIM Class 3 area based on the discussion above, and the presumption that if residual radioactivity is present, its concentration will not exceed a small fraction of the acceptance criteria.
The discussion and evaluation (survey) below will show that the classification was overly conservative and without sentinel and FSS measurements which have now been performed.
4 Hard to detect (HTDs) are non-gamma emitters requiring special and costly analyses. HTDs at CR3 are H-3, C-14, Fe-55, Ni-59, Ni-63, Sr-90, Tc-99, Pu-239, and Am-241. Easy to detect (ETDs) include the gamma emitters Co-60, Cs-137, Eu-152, and Eu-154.
3F0225-01 / Attachment 1 / Page 26 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 The designation of CASA as a Class 3 impacted area in the HSA was because some dredged material from the East and West Settling Ponds was placed into the CASA area. A white paper, Estimate of CR3 Licensed Activity Transported to Units 4 & 5 Coal Ash Pile (CR3, 2022a) shows low levels of Cs-137 and a single sample from the East Pond (EP5) with a very low level of Co-60 (0.027 pCi/g) in 2009. However, some dredging from the East Pond was transferred to CASA two years later in 2011 and further evaluations have not shown any detectable levels of plant-related radionuclides for CASA. The white paper is included as part of the CASA FSS report in Attachment 4.
Importantly, four samples collected from the East Pond area just prior to the dredging were analyzed by gamma spectroscopy to CR3 ODCM environmental LLD levels. The only detectable plant-related gamma-emitter was Cs-137 at a maximum value of 0.027 pCi/g, which is within background variation. No other plant-related gamma-emitting radionuclides were detected. There is no indication that any of the dredging from the East Pond to CASA contained detectable levels of plant-related radionuclides.
A characterization campaign was conducted in March 2022 and nine samples were collected and analyzed for gamma emitters and sample 005 was sent offsite and counted for site-specific HTD radionuclides. Gamma results for sample 007 was positive for Cs-137 at 0.052 pCi/g, which is less than the background concentration guidance level of 0.132 pCi/g. The remainder of the sample gamma results did not indicate any plant derived radioisotopes. No HTD radionuclide was identified greater than the MDA for the analysis (ADP-CR3, 2024c). No Co-60 or HTDs have been detected in samples from CASA and all Cs-137 detected is considerably less than the 0.132 pCi/g maximum value for the background range.
The FSS was conducted in November 2024.
During November 2024, fifteen surficial soil samples were collected from the Survey Unit CASA and analyzed for gamma-emitting nuclides by the on-site laboratory using APEX-Gamma spectroscopy. Two samples were randomly selected and submitted to GEL Laboratories, LLC. (GEL) for analysis of hard-to-detect (HTD) radionuclide analysis.
For quality assurance/quality control (QA/QC) purposes, a split and a recount sample were collected/analyzed per survey area. No quality QA/QC issues were noted that impact on the overall confidence of the results nor the conclusions of the surveys.
Results of the FSS are that no plant related activity was identified.
Also, during November 2024, an additional 45 samples were collected where the 15 surficial samples were collected earlier in November. The samples were composited from 0-3 feet, 3 to 6 feet, and 6 to 9 feet. All were analyzed for gamma-emitting nuclides by the on-site laboratory using APEX-Gamma spectroscopy. Six samples were randomly selected and submitted to GEL Laboratories, LLC. (GEL) for analysis of hard-to-detect (HTD) radionuclide analysis.
For quality assurance/quality control (QA/QC) purposes, a split and a recount sample were collected/analyzed per survey area. No quality QA/QC issues were noted that impact on the overall confidence of the results nor the conclusions of the surveys. Results of the FSS are that no plant related activity was identified.
3F0225-01 / Attachment 1 / Page 27 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 The FSS survey details are provided in the Attached report, CR3 CASA Area Partial Site Release Phase II Report, (ADP-CR3, 2024f). The survey unit is considered indistinguishable from background.
SEAL - SeaLand Container Storage Area Survey Area SEAL is located outside the PA and encompasses approximately 2,712 m2 or 0.67 acres of land inside of the railroad loop. RAM was stored in SeaLand containers that were staged in this area during Refuel Outage #16. It is bounded by NIA-06 on all sides.
This area was preliminarily classified as MARSSIM Class 3; however, based on historical information, the discussion, and evaluations (surveys) below will show that the classification was overly conservative and without sentinel and FSS measurements which have now been performed.
In March of 2022, a Site Characterization was done. For the SeaLand area, a total of six samples were collected and analyzed for gamma emitters and sample 001 was sent off site and counted for site-specific HTD radionuclides. No plant-related radionuclides were detected above the MDAs (CR3, 2022c).
The FSS, Attachment 5, was conducted in November 2024, nineteen surficial soil samples were collected from the Survey Unit SEAL and analyzed for gamma-emitting nuclides by the on-site laboratory using APEX-Gamma spectroscopy. Two samples were randomly selected and submitted to GEL Laboratories, LLC. (GEL) for analysis of hard-to-detect (HTD) radionuclide analysis. For quality assurance/quality control (QA/QC) purposes, two split and two recount samples were collected/analyzed per survey area.
No quality QA/QC issues were noted that would impact on the overall confidence of the results nor the conclusions of the surveys. Results of the FSS are that no plant related activity other than Cs-137 was identified above MDA values and that Cs-137 levels were within the normal background threshold of 0.132 pCi/g. The survey details are provided in the enclosed report, CR3 SeaLand Area Partial Site Release Phase II Report, (ADP-CR3, 2024g).
The survey unit is considered indistinguishable from background.
For the 10 CFR 50.83(b) requirements:
(1) Results of Evaluations and Confirmatory Measurements MARSSIM Section 2.5.2 states, "Non-impacted areas represent areas where all of the information necessary to demonstrate compliance is available from existing sources. For these areas, no statistical tests are considered necessary." Additionally, Table 2.2 of MARSSIM, "Recommended Conditions for Demonstrating Compliance Based on Survey Unit Classification for a Final Status Survey," requires no elevated measurement comparison, no sampling, and/or direct measurements and no scanning to be performed in non-impacted areas. Despite this available waiver, a comprehensive survey was carried out.
The only potential impact on NIA areas from the site would have been due to airborne releases from the reactor or other site facilities. Any impact from the site airborne releases would have 3F0225-01 / Attachment 1 / Page 28 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 been fairly uniformly dispersed across areas of interest. The confirmatory survey for each of the NIA was designed and executed using the guidance provided in MARSSIM and NUREG-1757, Volume 2, Revision 2. Specifically, the MARSSIM Class 3 model for survey design, measurement or sample locations were prescribed at randomly chosen locations and biased survey measurement locations and scan areas. Both data quality objectives and survey methodology were included in detailed survey packages. These describe the process, organization, functional sample activities, Data Quality Objective process, and measures necessary to conduct surveys in the field. The surveys were carried out via those detailed survey package documents.
From April 28 to May 12, 2023, sufficient survey coverage and an adequate number of samples were obtained in the subject survey areas to serve as the basis for the non-impacted classification. The validation survey design utilized a graded approach with scan and sampling frequencies based on the potential for contamination concentrations in excess of the release criteria. In general, the radiological release surveys consisted of the following activities:
Gamma walkover surveys of open land areas using a 2 x 2 NaI detector, Surface soil, sediment, or other bulk material sampling for gamma spectroscopy, and HTD analysis including tritium analysis.
The validation surveys performed in support of partial site release were designed, implemented, and data assessed using guidance provided in MARSSIM. The full validation measurement report is found in Attachment 11, CHAR-06 CR3 Non-impacted Open Land Survey Areas, (ADP-CR3, 2024c) which includes on site laboratory and offsite laboratory analytical results. A survey plan was developed for each NIA. Each plan included the seven-step Data Quality Objectives (DQO), identification of sample locations with GPS, instrument response checks, percent scanning requirement with audible feature activated, pre job brief on job hazard, training, how many samples to collect and methodology of collection, sample control and custody, bias sample locations, and a prospective power curve.
A Principal Study Question (PSQ) of the validation measurement survey was: Are radionuclide concentrations in the non-impacted land area consistent with available regional background data and ROC statistical parameters? An acceptable response to the PSQ for this work is background is achieved when Cs-137 results do not exceed the sites earlier PSR criterion of 0.132 pCi/g with no other identification of plant related ROCs greater than MDA.
3F0225-01 / Attachment 1 / Page 29 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 As illustrated in Attachment 2, between April 28 and May 12, 2023, a total of 113 surficial soil samples were collected from the above listed survey areas and analyzed for gamma-emitting nuclides by the on-site laboratory using APEX-Gamma spectroscopy:
NIA-01: Two samples showed trace amounts of Cs-137 activity at 5.00E-02 picocuries per gram (pCi/g) and 5.79E-02 pCi/g which is well below the background assessment value of 1.32E-01 pCi/g with no other identification of plant related radionuclides-of-concern (ROCs).
NIA-02: Two samples showed trace amounts of Cs-137 activity at 9.18E-02 pCi/g and 5.47E-02 pCi/g which are well below the background assessment value of 1.32E-01 pCi/g with no other identification of plant related ROCs detected.
NIA-03: Five samples showed trace amounts of Cs-137 activity at 7.20E-02 pCi/g, 4.32E-02 pCi/g, 8.57E-02 pCi/g, 9.72E-02 pCi/g, and 6.66E-02 pCi/g which are well below the background assessment value of 1.32E-01 pCi/g with no other identification of plant related ROCs detected.
NIA-04: Seven samples showed small trace amounts of Cs-137 activity at 2.45E-02 pCi/g, 3.55E-02 pCi/g, 5.59E-02 pCi/g, 6.18E-02 pCi/g, 3.92E-02 pCi/g, 2.79E-02 pCi/g, and 5.06E-02 pCi/g which are well below the background assessment value of 1.32E-01 pCi/g with no other identification of plant related ROCs detected.
NIA-05: Seventeen samples showed trace amounts of Cs-137 activity at 1.12E-01 pCi/g, 4.60E-02 pCi/g, 1.74E-01 pCi/g, 3.17E-02 pCi/g, 3.67E-02 pCi/g, 7.03E-02 pCi/g, 5.52E-02 pCi/g, 1.11E-01 pCi/g, 5.08E-02 pCi/g, 9.79E-02 pCi/g, 1.52E-01 pCi/g, 1.18E-01 pCi/g, 7.97E-02 pCi/g, 9.32E-02 pCi/g, 5.54E-02 pCi/g, 1.07E-01 pCi/g, and 4.66E-02 pCi/g, which are below the background assessment value of 1.32E-01 pCi/g with the exception of two samples; (NIA-05-004 and NIA-05-021-B with Cs-137 at 1.74E-01 pCi/g and 1.52E-01 pCi/g, respectively.
Investigative samples were taken at/near the two sample locations above the PSR background levels. All analytical results were below the background assessment value of 1.32E-01 pCi/g with no other identification of plant related ROCs.
The measurable levels of Cs-137 for area NIA-05 are within the statistical variation of background values as measured for the site for the previous PSR. The levels were within the 99% upper confidence level of 1.96E-01 pCi/g for background, which is not uncharacteristic of background level variations considering different soil compositions.
(ADP-CR3, 2024c).
NIA-06: One sample showed trace amounts of Cs-137 activity at 3.17E-02 pCi/g which is well below the background assessment value of 1.32E-01 pCi/g with no other identification of plant related ROCs detected.
3F0225-01 / Attachment 1 / Page 30 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 Twelve samples were randomly selected and submitted to GEL Laboratories, LLC. (GEL) for hard-to-detect (HTD) radionuclide analysis. For quality assurance/quality control (QA/QC) purposes, two split and two recount samples were collected/analyzed per survey area. No quality QA/QC issues were noted that would impact the overall confidence of the results nor the conclusions of the surveys herein. Only 5 samples presented trace amounts of Cs-137, and they were considered within the background range and well below the background assessment value of 0.132 pCi/g. Table 3 presents the results of samples analyzed at the off-site laboratory with only results greater than the minimum detectable activity (MDA) highlighted, e.g., Cs-137.
Table 3 Summary of Offsite Analysis of Gamma and HTDs for NIA (pCi/g)
ROC NIA-06-008 NIA-06-005 NIA-05-002 NIA-05-016 NIA 002 NIA 003 NIA-02-006 NIA-02-009 NIA-03-009 NIA-03-013 NIA-04-002 NIA-04-017 Average H-3
-36
-9.75 33.7
-85.9
-88.5 66 5.34
-49.1 86.6
-47.2
-37.3 7.5 16.6 C-14
-0.95 2.55
-0.58 0.285
-1.23 0.14
-2.58
-0.1 0.77
-1.79 2.45
-0.89 0.52 Fe-55 25.4
-0.1 15.5 12.3 26.6 17.5 12 0.7 0.9 3
34.9
-4.1 12.4 Co-60
-0.02 0.003
-0.01 0.002
-0.005
-0.001 0
-0.003 0.003 0
0 0.004 0.001 Ni-59
-0.23 2
0
-41
-4.2
-0.12
-5.06
-17.1
-1.09 6.7
-10.3
-29.5 0.73 Ni-63
-2.11
-4.98
-0.76 2.28
-3.99 1.36 1.84 0.42
-2.26
-5.13
-5.86
-4.62 0.49 Sr-90
-0.01 0.024 0.003
-0.014
-0.004
-0.005
-0.08 0.038 0
0.028
-0.01 0
0.005 Tc-99
-0.54
-2.71
-1.06
-0.331
-2.34
-0.842
-2.2
-1.1
-0.99
-1.06
-1.87
-1.93 0
Cs-137 0.012 0.017 0.005 0.013 0.004 0.002 0.004 0.001 0.028
-0.001 0.018 0.01 0.01 Eu-152 0.01 0.005 0
-0.007
-0.004
-0.009
-0.02 0.006
-0.02 0.001 0
0 0.002 Eu-154 0.004 0.004 0.008 0.004
-0.008 0.004 0
0.009 0.006 0.004 0
0 0.004 Pu-239 0.126 0.009 0.032 0.071
-0.012 0.024 0.029 0.034
-0.03 0.036 0.027 0.06 0.037 Am-241 0
0.099
-0.02
-0.041 0.0399 0.0218
-0.08 0.0847
-0.01 0
0.044 0.06 0.03 Highlighted cells are > MDA. Negative values are applied as zeroes in averaging.
Samples were collected, analyzed on-site with gamma spectroscopy, and 10% sent off-site for gamma spectroscopy and HTDs. All sample results were considered within background statistical limits (ADP-CR3, 2024c).
From April 28 to May 12, 2023, sufficient survey coverage and an adequate number of samples were obtained in the subject survey areas to serve as the basis for the non-impacted classification. The validation survey design utilized a graded approach with scan and sampling frequencies based on the potential for contamination concentrations in excess of the release criteria. In general, the radiological release surveys consisted of the following activities:
Gamma walkover surveys of open land areas using a 2 x 2 NaI detector, and Surface soil, sediment, or other bulk material sampling for gamma spectroscopy and HTD analysis including tritium analysis.
3F0225-01 / Attachment 1 / Page 31 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 The validation surveys performed in support of partial site release were designed, implemented, and data assessed using guidance provided in MARSSIM. The full validation measurement report is, CR3 Non-impacted Open Land Survey Areas, (ADP-CR3, 2024c) which includes on-site and offsite analytical results. A survey plan was developed for each NIA. Each plan included the seven-step Data Quality Objectives (DQO), identification of sample locations with GPS, instrument response checks, percent scanning requirement with audible feature activated, pre-job brief on job hazard, training, how many samples to collect and methodology of collection, sample control and custody, bias sample locations, and prospective power curves.
In general, non-impacted survey areas had a gamma scan survey performed over 1% of the accessible surface areas. It was not always possible to scan in some areas where safe access was a factor, alternate locations were selected. If during the scan survey an area of elevated activity was identified (typically defined as a reading in excess of the instrument Minimum Detectable Count Rate (MDCR) plus ambient background), then the elevated area(s) were bounded, and an investigation was performed.
A total of 30,000 m2 was scanned using a Model 2241 paired with a Model 44-10 NaI detector.
Alarm set-points for the instrument were set at the observed background plus the MDCR of the instrument. Measurement statistics for the NIA include the average background of 6,039 cpm with a sigma of 3,115 cpm, minimum of 3,419 cpm and a maximum of 14,346 cpm. All alarms were investigated, and soil samples were taken at locations where the elevated reading was verified. In NIA-05, six (6) instrument alarms were logged. In all instances, the elevated readings were attributed to NORM.
A Principal Study Question (PSQ) of the validation measurement survey was: Are radionuclide concentrations in the non-impacted land area consistent with available regional background data and ROC statistical parameters? An acceptable response to the PSQ for this work is background is achieved when Cs-137 results do not exceed the sites earlier PSR criterion of 0.132 pCi/g with no other identification of plant related ROCs greater than MDA. Radioactivity levels are within natural background ranges with no plant related radionuclides identified, the survey meets the requirements of 10 CFR 20.1402 as a de facto indistinguishable from background criterion.
(2) A description of the part of the facility or site to be released:
ADP-CR3 has agreed to return approximately 618 acres for CREC use as shown in Figure 3 to Duke Energy. The land has been evaluated to contain no identifiable residual radioactive material. The description was provided earlier in this document. Additional information may be found in Attachments 2 through 5, 10, and 11.
(3) Schedule for release of the property:
For non-impacted areas, 10 CFR 50.83(b)(3) requires a schedule for the release of the property.
ADP-CR3 intends to begin undertaking activities associated with the release of the subject property from the Part 50 License on or before April 30, 2025. Therefore, ADP-CR3 requests that the NRC approve the acceptability of the release of the subject property from the Part 50 3F0225-01 / Attachment 1 / Page 32 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 License by April 30, 2025. ADP-CR3 will return the non-impacted portion to Duke Energy as soon as possible upon NRC approval as a partial site release.
For the 10 CFR 50.83(d) requirements:
(1) The information specified in paragraphs (b)(1) through (b)(3) of this section.
ADP-CR3 has provided this information in the preceding portion of this letter identified accordingly.
(2) The methods used for and the results obtained from the radiation surveys required to demonstrate compliance with the radiological criteria for unrestricted use specified in 10 CFR 20.1402.
ADP-CR3 has provided this information in the preceding portion of this letter beginning with the section addressing 10 CFR 50.83(a)(3).
(3) A supplement to the environmental report, under §51.53. describing any new information or significant environmental change associated with the licensees proposed release of the property.
The NRCs Environmental Assessment for the License Termination Plan for Crystal River, Unit 3 in Citrus County was issued in July 2024 (NRC, 2024): 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.
Also recently, in connection with the development of the License Termination Plan (LTP),
Chapter 8, "Supplement to the Environmental Report," was prepared to describe any new information or significant environmental changes associated with the site-specific decommissioning and site closure activities performed at CR3.
The supplement includes a detailed description of the remaining decommissioning and site closure activities, the interaction between those activities and the environment, and the likely environmental impact of those activities. The supplement discusses whether the activities and their impacts are bound by the impacts predicted in the original FSS. Chapter 8 of the LTP concludes the non-radiological environmental impacts from decommissioning are temporary and not significant.
The proposed PSR propertys current use of the land is part of the CREC. Samples taken in the area do not indicate impact from licensed activities. Because the power reactor is shut down and there is no evidence of historic impact on the NIA or impacted land areas, any previous environmental impact statements should not be impacted by the proposed release.
ADP-CR3 has evaluated the environmental impacts associated with the proposed release of the subject property and considered those impacts in light of the original FSS. The evaluation did not identify any significant new environmental impacts or any significant changes from the environmental impacts previously assessed. In particular, the evaluation found as follows:
The land transfer will have no increase in offsite dose consequences and no change in effluent releases.
3F0225-01 / Attachment 1 / Page 33 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 The CR3 radiological monitoring program will account for the revised site area boundary, and no increases in effects are anticipated.
Accordingly, ADP-CR3 concludes that the environmental impacts associated with the proposed release of the subject property are bound by the NRC' s previous or current review, of the CR3 facility.
Based on the results of radiological surveys performed in support of partial site release, along with the reviews and assessments described above, the release of the subject property from the CR3 Part 50 License has no impact on ADP-CR3s continued compliance with applicable NRC regulatory standards.
ADP-CR3 has determined under 10 CFR 50.83 that we have adequately evaluated the effect of releasing the subject property, that the subject property has been properly classified as non-impacted, and that the release of the property will not have any adverse impact on public health or safety or adverse impact on the ability of the site in aggregate to meet 10 CFR Part 20, Subpart E, criteria for unrestricted release. Accordingly, ADP-CR3 is requesting the NRC to approve the requested release of the subject property under the provisions of 10 CFR 50.83.
3F0225-01 / Attachment 1 / Page 34 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 REFERENCES ADP-CR3, Accelerated Decommissioning Partners (ADP-CR3). 2022 Annual Radiological Environmental Operating Report, April 18, 2023. ADAMS Accession Number ML23108A266.
ADP-CR3, CR3 Non-impacted Areas Partial Site Release Phase II Report, 2024a. Attachment 2.
ADP-CR3, Annual Radiological Environmental Operating Report 2023, April 30, 2024b. ADAMS Accession Number ML24121A121.
ADP-CR3, CHAR-06 CR3 Non-impacted Open Land Survey Areas, 2024c. Attachment 11.
ADP-CR3, CHAR-01 Impacted Open Land Survey Areas, 2024d. Attachment 10.
ADP-CR3, CR3 R16Y Area Partial Site Release Phase II Report, 2024e. Attachment 3.
ADP-CR3, CR3 CASA Area Partial Site Release Phase II Report, 2024f. Attachment 4.
ADP-CR3, CR3 SeaLand Area Partial Site Release Phase II Report, 2024g. Attachment 5.
ADP-CR3, Basis for No Contaminated Water Dose at CR3, 2024h. Attachment 9.
CFR, Code of Federal Regulations, 10 CFR 50.83, Release of Part of a Power Reactor Facility or Site for Unrestricted Use, 2024a.
CFR, Title 10, Part 20, Subpart D, Radiation Dose Limits for Individual Members of the Public, 2024b.
CFR, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination, 2024c.
CFR, Title 10, Part 100, Reactor Site Criteria.2024d.
CR3, Crystal River Unit 3, PSDAR, Post-Shutdown Decommissioning Activities Report," 20193.
ADAMS Accession Number ML19177A080.
CR3, Estimate of CR3 Licensed Activity Transported to Units 4 & 5 Coal Ash Pile, 2022a. Part of.
CR3, HPP-333 Dose Calculations for Members of the Public and Unmonitored Occupational Individuals, August 17, 2022b.
CR3, CR3 SeaLand Reclassification Position Paper, September 12, 2022c. Part of Attachment 5.
Duke Energy. Crystal River Unit 3 - Partial Site Release Request, 2019. ADAMS Accession Number ML19022A076. Attachment 7.
3F0225-01 / Attachment 1 / Page 35 of 36
ADP CR3, LLC 15760 West Power Line Street l Crystal River, FL 34428 H&A, Haley & Alrich. Groundwater Well and Withdrawal Permit Limits Under the Florida Department of Environmental Protection Regulations, and February 28, 2024 and March 21, 2024. Attachment 8.
NEI, Nuclear Energy Institute. NEI 99-04. Guidelines for Managing NRC Commitment Changes, July 1999. ADAMS Accession Number ML003680088.
NRC, U.S. Nuclear Regulatory Commission. Regulatory Guide 1.179, Revision 2, Standard Format and Contents for License Termination Plans for Nuclear Power Reactors, 2019.
NRC, NUREG-1575, Revision 1, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), August 2000.
NRC, NUREG-1757, Volume 2, Revision 2, Consolidated Decommissioning Guidance Characterization, Survey, and Determination of Radiological Criteria - Final Report, July 2022.
NRC, Environmental Assessment for the License Termination Plan for Crystal River, Unit 3 in Citrus County, ADAMS Accession Number ML24081A068. July 2024.
RSCS, Radiation Safety and Control Service, Historical Site Assessment for Crystal River 3, June 2016. Attachment 6.
3F0225-01 / Attachment 1 / Page 36 of 36