ML25156A234
| ML25156A234 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  (DPR-072) |
| Issue date: | 06/17/2025 |
| From: | William Allen Reactor Decommissioning Branch |
| To: | Reid B ADP CR3 |
| Shared Package | |
| ML25156A231 | List: |
| References | |
| EPID L-2025-LLA-0033 | |
| Download: ML25156A234 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Billy Reid, Site Executive ADP CR3, LLC 157060 West Power Line Street Crystal River, FL 34428
SUBJECT:
AUDIT REPORT FOR ACCELERATED DECOMMISSIONING PARTNERS PARTIAL SITE RELEASE LICENSE AMENDMENT REQUEST TO REMOVE PROPERTY FROM THE CRYSTAL RIVER 3 FACILITY OPERATING LICENSE (EPID NO. L-2025-LLA-0033)
Dear Mr. Reid:
By letter dated February 10, 2025 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML25041A177) Accelerated Decommissioning Partners Crystal River Unit 3, LLC (ADP CR3) (the licensee) submitted a license amendment for Crystal River Unit 3. The proposed amendment would 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).
Enclosed is a report on a regulatory audit conducted by the NRC staff from May 12, 2025, to May 29, 2025, in connection with its review of the licensees application. The audit report does not make any regulatory conclusions or findings. However, it is part of the administrative record of the NRC staffs review of the application and may provide information supporting the NRC staffs safety evaluation of the application. The audit followed the plan provided by letter dated May 1, 2025 (ADAMS Accession No. ML25119A030), unless otherwise noted in the enclosed report.
June 17, 2025
B. Reid 2
In accordance with 10 CFR 2.390 of the NRCs 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 NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. If you have any questions, please contact me at (301)-415-6877 or by electronic mail at william.allen@nrc.gov.
Sincerely, Chris Allen, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Projects Office of Nuclear Material Safety and Safeguards Docket No. 50-302 License No. DPR-72 EPID No. L-2025-LLA-0033
Enclosure:
Audit Report cc w/enclosure: Crystal River Listserv Signed by Allen, William on 06/17/25
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Enclosure OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS REGULATORY AUDIT
SUMMARY
REGARDING LICENSE AMENDMENT REQUEST BY ACCELERATED DECOMMISSIONING PARTNERS CRYSTAL RIVER UNIT 3 TO APPROVE A PARTIAL SITE RELEASE REQUEST CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302
1.0 BACKGROUND
By letter dated February 10, 2025 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML25041A177) Accelerated Decommissioning Partners Crystal River Unit 3, LLC (ADP CR3) (the licensee) submitted a license amendment for Crystal River Unit 3. The proposed amendment would remove 618 acres of property, classified as either radiologically non-impacted or Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) 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).
This report summarizes the regulatory audit conducted by the NRC staff from May 12, 2025, to May 29, 2025, in connection with its review of the licensees application. The audit report does not make any regulatory conclusions or findings. However, it is part of the administrative record of the NRC staffs review of the application and may provide information supporting the NRC staffs safety evaluation. The audit followed the plan provided by letter dated May 1, 2025 (ADAMS Accession No. ML25119A030) unless otherwise noted in this audit report.
2.0 AUDIT REGULATORY BASIS Title 10 of the Code of Federal Regulations (10 CFR) 50.83 requires power reactor licensees to provide enough information for the NRC to determine if the classification of any release area as non-impacted is justified and if the licensees radiation survey for an impacted area is adequate.
NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) 3.0 AUDIT SCOPE AND ACTIVITIES The purpose of the audit was for the NRC staff to gain a more detailed understanding of the applicants proposed partial site release (PSR). The audit was also performed to identify any information that will require docketing to support the NRC staffs development of the safety evaluation report. The NRC staff issued the audit plan on May 1, 2025 (ADAMS Accession No. ML25119A030). The NRC staff provided the applicant an initial set of audit questions on May 1, 2025 (ADAMS Package Accession No. ML25156A237) after reviewing the application. The regulatory audit was conducted virtually from May 12, 2025, to May 29, 2025. During the May 12, 2025, entrance meeting, the staff provided an overview of the topics referenced in the audit plan (ADAMS Accession No. ML25119A030). The applicant addressed the audit plan topics over the course of multiple audit meetings. The applicant provided requested documents and draft responses via an online portal which the licensee had previously established for review of a License Termination Plan (LTP). The online portal allowed the NRC staff to view documents remotely via the internet, but did not allow them to download or print the documents.
4.0 AUDIT RESULTS The licensee committed to changing several sections of the application during the audit discussions and to subsequently submit the revised sections on the docket. The NRC staff conveyed that the commitments by the licensee should adequately address the NRC staffs concerns; however, the NRC staff explained that requests for additional information may still be necessary. The table provided in the attachment to this audit report outlines the basis for each discussion topic along with the proposed path to resolution.
5.0 AUDIT
SUMMARY
The licensee committed to changing several sections of the application during the audit discussions and to subsequently submit the revised sections on the docket. The NRC staff conveyed that the commitments by the licensee should adequately address the NRC staffs concerns; however, the NRC staff explained that requests for additional information may still be necessary. The table provided in the attachment to this audit report outlines the basis for each discussion topic along with the proposed path to resolution. Summaries of the various topics discussed are provided below.
A. Groundwater Groundwater discussions primarily focused on two areas. The first area was the brackish groundwater conceptual site model (e.g., boundary conditions, initial conditions, etc.) as well as groundwater uses (e.g., drinking water, irrigation, or stock). The second area was the potential for groundwater contamination. The applicant took the position that there is no residual radioactivity in the groundwater of the PSR areas. The applicant compiled data from their previous LTP request and results from a follow-up sampling event to support their position. The support included averages from the two data sets being below the value associated with the critical level (Lc), radionuclide results above the Lc in the first data set were below the Lc in the second data set, and all results were near the Lc or below. In addition, the applicant suggested that tritium, as an indicator radionuclide for residual radioactivity, was below the Lc values in all samples for both sampling events. In addition to addressing the presence of groundwater contamination, the data provided by the applicant clarified from which wells samples were obtained to generate the data associated with the previous LTP. Because the applicant chose to demonstrate that previous indicators of residual contamination were false positives, water quality information was not provided during the audit.
B. Indistinguishable from Background Indistinguishable from background discussions covered the applicability of the original background reference areas (BRAs) to the Phase II PSR land areas, the use of Minimum Detectable Concentration (MDC) values versus actual concentrations, the use of judgmental versus random sampling data to determine the original indistinguishable from background concentration and a lack of the required statistical tests to demonstrate that the PSR land areas were indistinguishable from background concentration. After evaluating their options, the applicant chose to split two of the original BRAs, which have similar characteristics to the Phase II PSR survey units, into four reference areas and conduct a resampling effort in these areas to establish a new background concentration for use in the indistinguishable from background determination for the Phase II PSR. Random sample locations will be chosen in the new BRAs along with a back-up set of random sample locations in case samples cannot be collected at the initial random sample coordinates. The new samples will be analyzed allowing the licensee to establish an indistinguishable from background concentration for Cs-137 based on actual sample results. Subsequently, the licensee will conduct the appropriate statistical tests to demonstrate that the residual radioactivity in the survey units is indistinguishable from background.
C. Coal Ash Storage Area (CASA)
CASA discussions initially focused on identifying historical information on the sediment taken from the settling ponds and deposited in the CASA (e.g., amount of sediment deposited, radioactive material information, etc.) as well as the sampling and scanning efforts necessary to demonstrate compliance with the regulations. However, the applicant proposed reclassifying the CASA as non-impacted based on new information. December 13, 2011, sampling data indicates that the sediment dredged from the settling ponds contained no plant derived activity above background levels. Furthermore, it is believed that an effort to remediate coal ash heavy metals in the ground water in 2016 or 2017 resulted in the removal of the settling pond sediment. The applicant documented the new information in a report and placed it in the online portal. Verification that the settling pond dredge is less than the revised background concentration discussed above under Item B will resolve the staffs concerns.
D. Isolation and Controls Isolation and controls discussions focused on preventing the spread of contamination beyond the new proposed site boundary and evaluating all migration pathways from the remaining onsite areas to the proposed PSR areas. The applicant provided NS-FSS-04, "Isolation and Controls of Areas for Final Status Survey" which addressed several questions the NRC staff raised. In addition, the applicant committed to updating the application to summarize an evaluation of the migration pathways from the site to the adjacent PSR areas, but particularly to the southeast into NIA-06 in consideration of site groundwater flow patterns. The evaluation will address isolation and control measures as well as both surface and subsurface migration pathways. The evaluation will also account for both natural processes and decommissioning actions.
E. Classification/Reclassification Classification/Reclassification discussions focused on clarifying the decision associated with classification of particular survey units. After the discussions, the applicant opted to remove statements related to downgrading R16Y from a Class 3 area to a non-impacted area (NIA).
The applicant stated the residual radioactivity in the Class 1 and Class 2 Discharge Canal survey units bordering the NIA-04 and NIA-05 survey units in the PSR was underwater and no remediation of this area was planned. However, the applicant committed to implementing appropriate radiological controls if their plans changed.
F. Number of Samples Discussions about the number of samples focused on identifying the necessary information to determine the required number of samples. The applicant stated that they used the standard MARSSIM method for calculating the required number of samples in the survey units. The applicant committed to revising the application to include the relative shift calculation and to identify the data used to calculate the standard deviation for the relative shift equation in the FSSRs for the Class 3 areas.
G. Scanning and Biases Sampling Scanning and biases sampling discussions sought to identify the location of information (e.g.,
scanning survey maps, minimum detectable count rate values, etc.) necessary to support releasing the PSR land areas and to clarify the difference between judgmental and investigative samples. The applicant explained that minimum detectable count rate values are routinely documented in the survey package. In addition, the applicant planned to update the application by including the necessary scanning survey maps. The applicant explained that investigative samples were obtained at the discretion of the technician when they encountered a hot spot.
Judgmental samples were taken in places where contamination may concentrate such as low-lying areas.
H. Scan Speed/Distance Scan speed/distance discussions focused on identifying the distance between the detector and land area surface as well as the scan speed for various survey units because these can impact detector sensitivity. The applicant agreed to incorporate the detector distance and scan speed in the application.
I.
Reporting Analytical Results Discussions about reporting analytical results sought to clarify how terms were defined and used within the application to better understand the results presented. During the discussions, the applicant explained the Lower Limit of Detection was established as a performance criterion to be evaluated on an annual basis. In the Offsite Dose Calculation Manual, it is used to calculate an a priori value and the same equation is used to determine an a posteriori sample MDC. For MARSSIM uses (e.g., statistical quantities and tests), the actual sample results for laboratory analyses should be reported as positive, negative, or zero. For the dose compliance determinations associated with surface soils, if the median for a radionuclide determined from the basic statistical quantities is negative, the value should be set to zero for the sum of fractions calculation and the subsequent survey unit dose determinations. For groundwater data, any values greater than the Lc contribute to a dose estimation while values less than the Lc are assumed to be zero (and thus a dose of zero). If the analytical result is between the Lc and MDC (a posteriori), the reported dose is determined by the reported result. If results are reported as <MDC, then the MDC should be used for a dose estimate. If actual result values are reported, then either the reported result or the MDC value can be used for dose estimates.
In addition, after discussing the use of the term Minimum Detectable Activity (MDA) in the laboratory reports for onsite analyses, the applicant committed to replacing the term MDA with MDC.
J.
Data Assessment Data assessment discussions sought to better understand the application by assisting NRC staff in understanding how the information supported demonstrating how the indistinguishable from background criteria was satisfied. The applicant committed to updating data and statistical quantities as necessary and to updating discrepancies between survey result summaries in two separate attachments. The discussions also identified that judgmental and investigative samples were inappropriate for inclusion in statistical evaluations. The applicant committed to updating the statistical analyses.
K. Miscellaneous/Errors Discussions about errors and miscellaneous issues covered various items in the application which the NRC staff needed the applicant to resolve or provide clarification. The discussions identified how to make the application clearer and assisted the NRC staff in understanding how the applicant had developed its data.
6.0 AUDIT PARTICIPANTS Provided below is a list of audit participants from the NRC, ADP CR3, and ADP CR3 consultants:
NRC Staff Chris Allen Christianne Ridge Kathryn Robertson-DeMers Randy Fedors Shaun Anderson ADP CR3 Bryant Akins Chuck Burtoff John Jernigan Marshall Blake ADP CR3 Consultants Claude Wiblin James Stewart Bland Nadia Glucksberg 6.0 DOCUMENTS REVIEWED Below is a list of documents that the NRC staff reviewed during the audit.
"HSA Licensed Footprint Meeting Minutes (25Feb2016).pdf" NS-FSS-19, Quality Assurance Project Plan December 2023 groundwater sampling event results for all 13 radionuclides in the initial suite presented in Table 2-26 in LTP, Rev. 2 Crystal River Unit 3 Radiological Nuclides of Concern for DCGL Development, Rev. 4 "History of the Settling Pond Radioactivity Levels and Work Activities"
ML25156A231; ML25156A234 OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP/RDB NAME RFedors KRobertson-DeMers WAllen SAnderson DATE Jun 5, 2025 Jun 6, 2025 Jun 6, 2025 Jun 17, 2025 OFFICE NMSS/DUWP/RDB NAME WAllen DATE Jun 17, 2025