ML25119A030
| ML25119A030 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/01/2025 |
| From: | William Allen Reactor Decommissioning Branch |
| To: | Reid B ADP CR3 |
| References | |
| EPID L-2025-LLA-0033 | |
| Download: ML25119A030 (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:
CRYSTAL RIVER UNIT 3, AUDIT PLAN IN SUPPORT OF ACCELERATED DECOMMISSIONING PARTNERS PARTIAL SITE RELEASE REQUEST (EPID NO. L-2025-LLA-0033)
Dear Billy Reid:
By letter dated February 10, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25041A177), Accelerated Decommissioning Partners Crystal River Unit 3, LLC (ADP CR3) (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) to remove 618 acres of property, classified as either radiologically non-impacted or Multi-Agency Radiation Survey and Site Investigation Manual Class 3, associated with the Crystal River Unit 3 Operating License. In addition, the application requested the NRC to remove another 3,854 acres of property, classified as radiologically non-impacted, from the Crystal River Unit 3 Operating License as approved on January 2, 2020 (ADAMS Accession No. ML19339G509). The U.S. Nuclear Regulatory Commission staff (NRC) is reviewing the LAR and has determined that a regulatory audit is necessary to complete its review. The corresponding regulatory audit plan is enclosed with this letter.
In accordance with Title 10 of the Code of Federal Regulations (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 e-mail 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
Enclosure:
Regulatory Audit Plan cc: CR-3 Listserv May 1, 2025 Signed by Allen, William on 05/01/25
1 REGULATORY AUDIT PLAN TO SUPPORT REVIEW OF ACCELERATED DECOMMISSIONING PARTNERS (ADP)
PARTIAL SITE RELEASE REQUEST FOR CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 I.
BACKGROUND By letter dated February 10, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25041A177), Accelerated Decommissioning Partners Crystal River Unit 3, LLC (ADP CR3) (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) to remove 618 acres of property, classified as either radiologically non-impacted or Multi-Agency Radiation Survey and Site Investigation Manual Class 3, associated with the Crystal River Unit 3 Operating License. In addition, the licensee requested the NRC to remove another 3,854 acres of property, classified as radiologically non-impacted, from the CR3 Operating License as approved on January 2, 2020 (ADAMS Accession No. ML19339G509).
II.
REGULATORY AUDIT BASES The proposed ADP CR3 request is being reviewed in accordance with the applicable regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, 10 CFR Part 20, Standards for Protection Against Radiation, and applicable guidance provided in NUREG-1757, Vol. 2, Rev. 2, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria and NUREG-1575 Multi-Agency Radiation Survey and Site Investigation Manual (ML22194A859 and ML003761445, respectively).
III.
REGULATORY SCOPE The audit will cover ADP CR3s indistinguishable from background methodologies, survey unit evaluations, groundwater evaluations and migration of radioactive material off-site. This audit will provide information necessary to complete the NRC staffs evaluation of the ADP CR3 PSR amendment request. The NRC staff will review basis documents to gain a better understanding of the ADP CR3 partial site release (PSR) amendment request. The regulatory audit may also identify additional information that will be required to be docketed to support the basis of the licensing decision.
IV.
NECESSARY INFORMATION AND MATERIALS FOR THE REGULATORY AUDIT The NRC audit team will require access to licensee personnel with detailed knowledge of the license amendment request, supporting methodology, and supporting documents used in the development of the license amendment request.
In addition, the following information needs have been identified below:
1.
HSA Licensed Footprint Meeting Minutes (25Feb2016).pdf.
2 2.
Documents describing the actions taken to prevent recontamination of survey units following Final Status Survey, e.g., isolation and control plans for the proposed site boundary, and evaluations of migration pathways from the remaining onsite areas to the proposed PSR areas.
3.
Groundwater data and technical documents.
a.
The conceptual site model for saline/freshwater distribution b.
Documentation that the berm area adjacent to the canals is representative of groundwater in the Phase II PSR areas.
c.
Well sample data from the proposed PSR release areas (e.g. CASA), and near the proposed boundary (e.g. NIA-06), that justifies designating PSR areas as non-impacted.
4.
Calculations and other technical documents associated with survey method and survey unit classification, survey unit sample acquisition and determination of statistical values.
a.
RESRAD-ONSITE *.rad files b.
Documentation that the background reference area physiographical and geological characteristics are representative of the Phase II PSR survey units.
c.
Historical information on the RAM deposited within the coal ash storage area, e.g.,
settling pond sampling information, amount of sediment deposited, deposition location, deposition methods, etc.
d.
Relative shift and Type II error calculations for each survey unit.
e.
Documents summarizing the R16Y and SEAL scan survey results.
f.
Documents identifying the surface to detector distance and the scan speed used for the R16Y and non-impacted survey units.
g.
Consistency of terminology used for reported analytical results.
Additional information needs may arise during the NRC staffs audit.
V.
AUDIT TEAM The NRC staff performing this audit will include, but may not be limited to, the following staff:
Audit Team Members Chris Allen (Audit Leader and Technical Reviewer)
Kathryn Robertson-DeMers (Technical Reviewer)
Randy Fedors (Technical Reviewer)
Christianne Ridge (Technical Reviewer)
VI.
LOGISTICS The audit will begin on May 12, 2025, with an entrance meeting at approximately 9:30 A.M.
Eastern Standard Time. Additional audit activities, such as daily status debriefs, will also be planned, as necessary, to support the understanding of information necessary to complete the review of the ADP CR3 amendment request. It is expected that additional interaction may be needed to identify information requests to support the review activities.
Completion of the audit is planned for May 16, 2025, with an exit meeting at approximately 3:00 P.M. Eastern Standard Time. The audit period may be reduced or extended, depending on the progress NRC and ADP CR3 staff make in addressing audit questions. If new technical items are identified, additional audit sessions may be needed to facilitate the continued review of the requested amendment.
3 The NRC and ADP CR3 staff will conduct this audit via either teleconference or video conference. The NRC staff will use an online reference document portal provided by ADP CR3 staff. Access to the online portal will be limited to specific NRC staff and the documents in the online portal are read-only (i.e., NRC staff will be prevented from saving, copying, downloading, or printing any documents). The conditions associated with the online reference document portal must be maintained throughout the review. The NRC staff who should be granted access to the portal are those listed in the Audit Team section above.
VII.
DELIVERABLES At the completion of the regulatory audit, the NRC staff will conduct an exit briefing and provide a summary of the audit results. The NRC staff plans to prepare a regulatory audit summary that will include the documents reviewed, the audit activities, and any requests for additional information that were discussed or that will be issued based on the audit, as applicable.
Ltr ML25119A030 OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP/RDB NAME RFedors KRobertson-DeMers WAllen SAnderson DATE Apr 29, 2025 Apr 30, 2025 Apr 29, 2025 Apr 30, 2025 OFFICE NMSS/DUWP/RDB NAME WAllen DATE May 1, 2025