ML25288A003
| ML25288A003 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/15/2025 |
| From: | ADP CR3 |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25228A001 | List: |
| References | |
| 3F1025-01 | |
| Download: ML25288A003 (1) | |
Text
ENCLOSURE 1 Crystal River Unit 3 Nuclear Generating Plant Docket Nos. 50-302 / 72-1035 Operating License DPR-72 Proposed Change 263 Description and Evaluation of the Proposed Changes Begins On Next Page lef 3F1025-01 / Enclosure 1
License Amendment Request, Change No. 263, Amend Facility Operating License 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). As a result, ADP CR3 proposes to amend Facility Operating License DPR-72 for CR3, to add License Condition 2.C.21, License Termination Plan (LTP).
2.0 BACKGROUND
CR3 is part of the larger Crystal River Energy Complex (CREC), which is located on the Gulf of Mexico in Citrus County, Florida. Duke Energy Florida (DEF) is the owner of the complex with ADP CR3 assuming control of CR3. This site's location is approximately 7.5 miles northwest of the City of Crystal River, and 70 miles north of Tampa. In addition to CR3, other structures on the CREC include two fossil-fueled units, two large cooling towers, coal delivery and storage areas, ash storage area, office buildings, warehouses, barge handling docks, and a railroad. Additionally, located outside the licensed footprint is two newly constructed Combined Cycle units which were added to the CREC. CR3 is located at latitude 28° 57' 25.87"N and longitude 82° 41' 55.95" W.
CR3 is a single unit pressurized light-water reactor (PWR) supplied by Babcock & Wilcox.
CR3 was initially licensed to operate at a maximum of 2,452 megawatt thermal (MWt). In 1981, 2002, and 2007, the NRC approved three DEF requests to increase the licensed core power level to a maximum power level of 2,609 MWt.
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 delaminated.
While completing repairs additional delamination occurred. CR3 was officially retired on February 5, 2013.
On April 1, 2020, the NRC approved transfer of CR3 from Duke Energy Florida, LLC (DEF) to ADP CR3, LLC (ADP CR3) to commence decontamination, dismantlement, and demolition (ADAMS Accession No. ML20069A023). On October 1, 2020, closing took place and ADP CR3 became the Facility Licensee and the updated PSDAR became effective changing the plant decommissioning strategy from SAFSTOR to DECON.
ADP CR3 is currently conducting decontamination and decommissioning (D&D) activities at the CR3 site in accordance with CR3 procedures and approved work packages. Final decommissioning activities are being coordinated with the appropriate Federal and State regulatory agencies. This will allow for the performance of activities to complete the site for license termination.
lef 3F1025-01 / Enclosure 1 / Page 1 of 6
3.0 PROPOSED CHANGE
ADP CR3 proposes to amend the Facility Operating License, which describes NRC approval of the LTP and provides criteria associated with future changes to the LTP that require prior NRC approval. Specifically, ADP CR3 proposes to add the following text to the Operating License as new License Condition 2.C.21;
- 21. License Termination Plan (LTP)
NRC License Amendment No. 263 approves the LTP. In addition to the criteria specified in 10 CFR 50.59 and 10 CFR 50.82(a)(6), a change to the LTP requires prior NRC approval if the change:
(a) Increases the probability of making a Type I decision error above the level stated in the LTP.
(b) Increases the radionuclide-specific derived concentration guideline levels (DCGL) and related minimum detectable concentrations.
(c) Increases the radioactivity level, relative to the applicable DCGL, at which investigation occurs.
(d) Changes the statistical test applied other than the Sign Test or Wilcoxon Rank Sum Test.
(e) Reclassifies a survey area from a more restrictive classification to a less restrictive classification (e.g., from a Class 2 to a Class 3 area) without providing the NRC a minimum 14 day notification before implementing the change in classification. A reclassification to a more restrictive classification (e.g., Class 2 to Class 1 area) may be done without prior NRC notification.
(f) Change the approach used to demonstrate compliance with the dose criteria.
(g) Change parameter values or pathway dose conversion used to calculate the dose such that the resultant dose is lower than in the approved LTP and if a dose assessment is being used to demonstrate compliance with the dose criteria.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements 4.1.1 10 CFR 50.82, Termination of License 10 CFR 50.82(a)(9) states All power reactor licensees must submit an application for termination of license. The application for termination of license must be accompanied or preceded by a license termination plan to be submitted for NRC approval.
(i) The license termination plan must be a supplement to the FSAR or equivalent and must be submitted at least 2 years before termination of the license date.
(ii) The license termination plan must include (A) A site characterization; (B) Identification of remaining dismantlement activities; (C) Plans for site remediation; (D) Detailed plans for the final radiation survey; (E) A description of the end use of the site, if restricted; lef 3F1025-01 / Enclosure 1 / Page 2 of 6
(F) An updated site-specific estimate of remaining decommissioning costs; (G) A supplement to the environmental report, pursuant to § 51.53, describing any new information or significant environmental change associated with the licensee's proposed termination activities; and (H) Identification of parts, if any, of the facility or site that were released for use before approval of the license termination plan.
4.1.2 10 CFR 50.82, Termination of License 10 CFR 50.82(a)(10) states If the license termination plan demonstrates that the remainder of decommissioning activities will be performed in accordance with the regulations in this chapter, will not be inimical to the common defense and security or to the health and safety of the public, and will not have a significant effect on the quality of the environment and after notice to interested persons, the Commission shall approve the plan, by license amendment, subject to such conditions and limitations as it deems appropriate and necessary and authorize implementation of the license termination plan.
4.1.3 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."
4.2 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:
4.2.1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
No.
The change allows for the approval of the LTP and provides the criteria for when changes to the LTP require prior NRC approval. This change does not affect possible initiating events for the decommissioning accidents previously evaluated in the CR3 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 boundaries used to evaluate compliance with liquid or gaseous effluent limits and has no impact on plant operations. Therefore, the proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
lef 3F1025-01 / Enclosure 1 / Page 3 of 6
4.2.2. 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.
There are sections of the LTP that refer to the decommissioning activities remaining (e.g.,
removal of large components, decontamination, etc.). 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 merely makes mention of these processes 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.
4.2.3. Does the proposed license amendment involve a significant reduction in a 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 boundaries used to evaluate compliance with liquid or gaseous effluent limits and has no impact on plant shutdown operations. Accordingly, neither the postulated accident assumptions in the DSAR, as updated, nor the Technical Specifications are affected. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
4.3 Environmental Considerations This amendment request satisfies the criteria specified in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements to perform an environmental assessment or to prepare an environmental impact statement. The criteria of 10 CFR 51.22(c)(9) are addressed as follows:
(i) The amendment involves no significant hazards consideration.
As discussed in the No Significant Hazards Consideration section above, the proposed license amendment does not involve significant hazards consideration.
(ii) There is no significant change in the types or significant increase in the amounts of effluents that may be released offsite.
The proposed license amendment is consistent with the plant activities described in the DSAR.
No changes in effluent system requirements or controls are proposed in this change. The environmental impacts associated with radiation dose to members of the public related to decommissioning activities and site release for unrestricted use were considered in NUREG-lef 3F1025-01 / Enclosure 1 / Page 4 of 6
0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, and NUREG-1496, "Generic Environmental Impact Statement in Support of the Rulemaking on Radiological Criteria for License Termination."
NUREG-0586 provides a generic environmental assessment of decommissioning a reference nuclear facility. Based on the findings in NUREG-0586, the NRC concluded a generic finding of "no significant (environmental) impact." The NRC further concluded that no additional Environmental Impact Statement would need to be prepared in connection with decommissioning a particular nuclear site unless the impacts of a particular plant have site-specific considerations significantly different from those studied generically. LTP Chapter 8 provides an updated assessment of the environmental effects of decommissioning CR3. The updated assessment also determined that the environmental effects from decommissioning CR3 are minimal and there are no adverse effects outside the bounds of NUREG-0586, Supplement 1. Based on the above, there will not be a significant change in the types or increase in the amounts of effluents released offsite for the remaining decommissioning activities. The release of effluents from the facility will continue to be controlled by site procedures throughout the remaining decommissioning, and the activities at CR3 will continue to be performed in accordance with the CR3 Offsite Dose Calculation Manual, as applicable.
(iii) There is no significant increase in individual or cumulative occupational exposure.
The attributes identified in NUREG-0586, Supplement 1 were compared with the remaining activities for CR3 and the following conclusions were made:
ADP CR3 will maintain annual occupational radiation exposure to individuals as low as reasonably achievable. These exposures will be at, or below, the estimated values in Table 4-1 of NUREG-0586, Supplement 1. LTP Section 3.4 provides a dose estimate for CR3 decommissioning.
ADP CR3 will maintain exposure to onsite workers and the offsite public from waste transportation well below the levels projected by NUREG-0586.
LTP Chapter 8 provides an updated assessment of the environmental effects of decommissioning CR3. The updated assessment also determined that the environmental effects from decommissioning CR3 are minimal and there are no adverse effects outside the bounds of NUREG-0586, Supplement 1. Additionally, 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.
Based on the above, there is no significant increase in individual or cumulative occupational exposure due to decommissioning CR3.
lef 3F1025-01 / Enclosure 1 / Page 5 of 6
4.4 Conclusion Based on the evaluations above: (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 the proposed amendment will not be inimical to the common defense and security or the health and safety of the public.
4.5 Precedent Plants that have underwent and are currently in the decommissioning process, such as Humboldt Bay Power Plant (ML13130A008), Zion Nuclear Power Station (ML15005A330),
and Fort Calhoun Station (ML24019A145), have revised their License to include the LTP approval and License requirements for maintaining the plant.
4.6 Pending Licensing Actions under NRC Review By letter dated February 10, 2025, CR3 submitted a License Amendment Request to remove property from the Facility Operating License associated with Partial Site Releases, Proposed Change 262 (Package ML25041A184). By letter dated June 18, 2025, CR3 submitted an updated License Amendment Request for the removal of these properties associated with the Partial Site Releases (ML25170A018).
lef 3F1025-01 / Enclosure 1 / Page 6 of 6