ML25288A018

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Enclosure 11 - ADP CR3, LLC, History of Settling Pond Activity Levels and Work Activity, May 20, 2025
ML25288A018
Person / Time
Site: Crystal River  Duke Energy icon.png
Issue date: 10/15/2025
From:
ADP CR3
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML25288A001 List:
References
3F1025-01
Download: ML25288A018 (1)
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Text

ENCLOSURE 11 Crystal River Unit 3 Nuclear Generating Plant Docket Nos. 50-302 / 72-1035 Operating License DPR-72 ADP CR3, LLC, History of settling pond activity levels and work activity Begins On Next Page lef 3F1025-01 / Enclosure 11

A1 ADP CR3, LLC 15760 West Power Line Street I Crystal River, FL 34428

Subject:

History of settling pond radioactivity levels and work activity Rev 5 Date: May 20th, 2025

Background

Section 6.3.4.14 of the Historical Site Assessment (HSA) documents that sediments were removed from the CR3 East and West Settling Ponds and deposited in the Unit 4 and 5 Coal Ash Storage Area (CASA). During past operations, CR3 infrequently released secondary liquid effluents to the East Settling Pond that contained trace levels of CR3 radioactive material. No discharges were made to the West Settling Pond. The HSA took the position that since the ponds had the potential for contaminated sediments and since sediment from the ponds were moved to CASA, then CASA should be classified as a MARSSIM Class 3 area. This HSA evaluation and classification recommendation did not adequately or completely consider the specifics of radiological controls implemented for the transfer in this recommendation, including sampling and analysis performed for the sediment removal. The CR3 Radiation Protection Program required sampling and analyses for radioactive material contamination prior to removal. If any plant-related radioactive material had been identified in the sediment, it would not have been transferred to CASA but would have been containerized and shipped as radwaste.

Water from the Station Drain Tank (SDT-1) and Turbine Building sump were occasionally batch released to the Settling Ponds, rather than to the discharge canal, when it contained chemicals not authorized by the NPDES permit. These chemicals were often associated with secondary side plant closed cycle cooling systems and included rust inhibitors such as NALCO or TTA, elevated hydrazine or other parameters exceeding the NPDES limits. The 2010 REMP report states that these discharges were being minimized through operational focus but were very infrequent even before 2010.

The West Settling Pond primarily received non-radioactive water from the Unit 1 and 2 coal plant boiler waste wash water and sewage treatment plant discharge water. Most of the sludge that built up in the pond was due to this Unit 1 and 2 discharge water and not from CR3 batch releases, which were relatively infrequent. The ponds are unlined and percolate into the groundwater below, which flows into the Gulf of Mexico just west of the ponds. These ponds stayed full of water for years and maintenance was considered only when the ponds were dry.

The CR3 Environmental group implemented a maintenance work activity to remove sediment and contour the sides of the East Settling Pond in December 2011. Vegetation and debris were removed from the sides of the ponds and excess sediment in specific spots were removed from the bottom.

The sediment removal occurred during the dry season when the ponds were most accessible. This is the only time material from the Settling Ponds were transferred to CASA. The Settling Ponds maintenance had been performed in the 1980's and 1990's. The material, if clean, was removed from site; and if radioactive material was identified, then the material was shipped as radwaste after sampling and not redeposited on or off site.

The goal of this white paper is to document historical data and operational work activities at the settling ponds. This recent information gathering is used to provide an update to the HSA which determines that CASA should be re-classified as a Non-Impacted Area.

Page 1 of 7 3F1025-01 / Enclosure 11 / Page 1 of 7

191 Description and Data Review

1. Direct Samples taken for sediment removal: The following four soil samples were collected from the East Settling Pond by a CR3 Chemistry Technician on December 13th, 2011, at the beginning of sediment contouring and removal, and counted on the gamma detector to CR3 ODCM environmental LLD's. The Chemistry Technician met the SMG contract excavator operator at the settling pond and went with the operator to each side of the pond to gather samples from the bottom of the pond where the sides met the bottom. The operator went into the bottom of the pond, retrieved the sediment sample then gave the samples to the Chemistry Technician. In two of the four samples Cs-137 was detected at background levels and the other two samples were less than MDC.

After determining the samples had no detectable plant-related radioactivity, above the known background Cs-137, and met requirements for unconditional release, the contract SMG operator was told the specific spots of material to be removed were clean and available for removal to CASA.

Figure 1, Sample Locations for the East Settling Pond lmagery@2019 Google, lmagery@2019 Maxar Teohnologies, U.S. Geological Survey, Map data ©2019 Note: green dots denote sample locations. Sample results are shown in table below.

Gamma Scan Sample ID Cs-137 activity pCi/o 13-DEC-2011-0001

<MDC 13-DEC-2011-0002

<MDC 13-DEC-2011-0003 1.623 E-2 13-DEC-2011-0004 2.716 E-2

2. Review of REMP Data: The State of Florida Department of Health (DOH) collects REMP samples for CR3 and has periodically collected soil samples from the Settling Ponds. The table summarizes past results:

Page 2 of 7 3F1025-01 / Enclosure 11 / Page 2 of 7

191 Table 1, Analytical Results for Soil Samples from Settling Pond Year Sample results ( oCi/ gm) 2009 0.190 - 0.299 (Cs137); 0.027 (Co-60) 2010 0.020 - 0.137 (Cs-137) 2011 0.076 - 0.097 (Cs-137) 2012 0.010 - 0.016 (Cs-137) 2013 0.006 - 0.008 (Cs-137) 2014 0.007 (Cs-137)

a. REMP soil and vegetation samples collected by State of Florida Department of Health in 2009: DOH collected 8 sediment and 8 vegetation samples in both the East and West Settling Ponds in 2009. Figure 2 below shows the general sample locations followed by analysis results. Summary of the analytical results are included in (Note:

DOH report is in pCi/Kg while CR3 discussion is in pCi/g or pCi/Kg.)

The 2009 results for the soil samples are shown below:

EAST SETTI.ING POND son. (i!CilkE, dry weidlt)

S=p!e Col!ecnmn Z!-95

&l-. 40 Site D:!i!e K-40

_ 111-54 Co,..58 Fe,-59 Co-60 Zln-65

~"b-95 1-131 Cs-14 Cs-137 La-140 (A)

(B)

EP

  • 0l-Se!]'"09 3500 = 19 6

<88

<46

<186 18

<6_

<50 64 = 8

<71 EP Ol-Se!]'"09 4052 = 2.>'I

<l 5

<56

" l

<19

<35

<37

<12.S EPl Ol-Se!)'"09* 1502.3 = 555

<68

<66

<l 8

<(fl

<90

< 2 43 =9

<105 EP4 Ol-Se!]"-09* 8895 = 340

<61

<58

<116

<54

<6:S

<98 EPS Ol-Se!]"-09 26~ = 1 0

'l

,2

<80 27 *= S

<16

<M

<54 299 = 15

<68 EP6

  • Ql-Se!]'"09 2682 = 1 4

_o

< 9

<38 2

<40

<37

'O

<2 37=9

< 89*

EP Ol-Se!]"-09* 5131 = 2 __

<31

_9

<51

<34

-=.:55

'6

<38 42=

<130 EP8 Ol-Se!]'"09 1702 = I A

_o

<rn

<3

<19

<42

' 4

<23

< 83 l!l.ESI S:EllLih"!:i POND SQIL (lll:il};,; do! p;eii:ht)

S:;,mp!e Coltec :0 111 Z!-95

&l-140 Site

~

K-40 Mn-54 Co,..SS Fe,-59 Co-60 ZD.-6*5 Nb-95 1-131 Cs-B4 Cs-137 La-140 (A)

(B)

WP

-ol-Se!]'"09* l 1068 = 223

_s

<25

<4 5,

<49 9

<40 7

<124 WP_

'°1-Sep-09* 26 1 *= 1

< 7

< 6

<31

<14

_5

<19*

<l WPl

-oJ-Se!]'"09 1556 = (i;J

<B

< 2

<22

<12

<53

<19

<14

<B

< H!

WP4 01-Se!]'"09* 2441 = 88

<14

< 3

<25

<U

-=.:55 0

<15 82 = 4

_o WPS

  • Ol-Sep-09* 703S = 181

< 8

<3

<19

<311 "9

<14

<30 190 = 12

<94 WP6 Se!]'"09 13006 = 447

<16

<6

<B

'1 56

<124

<100

<116 W!?

  • Ol-Sep-09 23 4 = 15 0

< 9,

<38

<44 "8

<ll

<26 82 = 10

<9 W!?S

-Ol-Se!]'"09 2409 = 84

<14

<13

<26

<13

<53 0

<15

<15

< _l (A) - These taimh'!°ed LD i;*a1ues for Zr,*1'11>-95 are tile hig er of the :illwvimlal p3l'E!llt or daughter LLD's.

(B) -Tbe,;etll:buhted LLD v:tl=

!!re ifor Ba-140,,ei er based on. direct measurement of Ba-40 or !based Oll ingrowth of 3-140, whic:b!;,;,er 111.1eihod yields the,grea er seD.Sili'\\*ity for a gi'l.'eo s:amp!e.

Co-60 was detected at a value of 2. ?E-2 pCi/g in one sample (EPS) in the east pond above MDC with the other 15 samples showing <MDC. The maximum Cs-137 concentration was 2.99E-1 pCi/g, also at location EPS.

Page 3 of 7 3F1025-01 / Enclosure 11 / Page 3 of 7

191 The 2009 vegetation results are as follows:

EAS SET G POND VEGE'FA TION ~illl.g.. *!ID we:i!l!l }

S21mple Go lectfon Zr-95 Ba-140 Site

....;!!g K-40

\\fu.-54 Co-5&

Fe-59 Co-60 Zn-65 Nb-95, I-B l Cs-134 Cs-137 La-40 (A)

)

EPl 03-Sep-09' 29 1 = 171

<14

<15 7

0 0

_5

<14

<18 2 = 6

<54 EP_

Ol-Sep-09* 2&4 = 166

<13

<13

<2:9

<17

<10

_o

<l

<14

<16

<53 EPl Ol-Sep-09 427 = 15-15

<13

<13

-15

<15

< YI

<.. 0

<14

<13 6-+/- 2

<34 EP'I Ol-Sep-09' 31. 4 = 143

<10

<9

_o

<l 4

< (I,

<15

<13 20 = 5

<38 EPS Ol-Sep-09 5165 = 224

<13

<14

<34

<J7 s:_2

<16 0

_2 = 10

<51 EP6 03-Sep-09' 4962 = 174

<13

<12

<31

<B

<l4

< IS

<14 19 = 3

.::15 EP71,VP1 Ol-Sep-09 4934 = 171

<13

<11

<l::i

<J_

_2

<19*

<13 (5,+/- 2

<16 EPS Ol-Sep-09 2241 = 161

<14

<12

<3&

<15

<L

_1

<:23

<17

_o

<:59 J.!lESI :il:Ill.ll£s:l: EDND VEGJU i?!,TION (JIC:~*ili~_ dll:mi:illl)

S2:mple Go lee *on Zr-95 Ba-140 Site

....;!!g K40

\\m-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95, I-131 Cs-134 Cs-13 La-40 (A)

' )

W? l Ol-Sep-09 31 Sl = 201

<:lS

<16

<37 0

<JS 9

<21

<17 2.8 = 7

<6,2.

'IJ.'P-Ol-Se!]'-09 1990 = 150 C::13

<:12

<32

<17

<4_

-4

<18

<18 19 = 9

<47

'l.l.'P3/EP7 Ol-Sep-09 493'1 = 171

<13

<11

<1::i

<3 2

c;: 19, C-.:13 (1,.+/- 2

<:16 W?4 Ol-Sep-09 4736 = 16-15

<12 C::12

<30

<B

<JS

_2

<19

<14 4 = 4-

<16 WPS Ol-Sep-09 %71 = 212

<:14 C::13

<-, "~

<2 __

<38

_1

<18

<18 35 = 9

<6&

WP6 Ol-Se!]'-09* 34l8 = 149 c;9

<9

-:.."27

<12 4

< 9

<: 14

<11

< JO

<:11 WP7 Ol-Sep-09 23 96 = 11&

c;9

<11

<12

_6

< 6

<16

<12 95 = 5

<43 WPS Ol-Sep-09 3S-7S = 1.57 c;9

<12 28

<13

_7

<19 c;: 19,

<12

< B

<:51 (A) - These tabula ed LLD,;alues for ZriNlJ.-95 are 1he higher of 1he iindi\\ti<i:ual p~,or daughter LLD's.

(B) - Tbec;eta:bulated LLD,*al'llec; :ID!* for Ba-140, ei er based on direct measur&11.ent ofBa-40 or based on ingm\\\\oi:h of -a-140, whiche,;er melhod yields the,grea er sensilil\\*i. for a gi11en samp*!e.

Cs-137 was the only radionuclide potentially of plant origin identified in the 16 vegetation samples, ranging from 6.0E-03 to 9.SE-02 pCi/g for the 12 samples above MDC.

b. Section IV-C.8 of the 2010 REMP reports states Cs-137 was detected in two of the four samples in concentrations ranging from 2.0E-2 to1.37E-1 pCi/g. There were no measurable amounts of Co-60 or Cs-134 in any of the four samples. It also states that tritium surface water samples were collected at two locations in the ponds. The tritium concentration was < LLD of 140 pCi/L in both samples. Both of these samples showed no measurable levels of plant-related radioactive material, above the known Cs-137 background.
c. Section IV-C.8 of the 2011 REMP reports states that sediment samples were collected at four locations in the site settling ponds. Cs-137 was detected in three of the four samples in concentrations ranging from 7.6E-2 to 9.?E-2 pCi/g. There were no measurable amounts of Co-60 or Cs-134 in any of the samples.
d. 2011 thru 2014 Samples. Pond sediment samples collected since 2011 have shown no detectable levels of plant-related radionuclides, except for Cs-137 which is present in the background rages as measured from the REMP.

Page 4 of 7 3F1025-01 / Enclosure 11 / Page 4 of 7

191 In summary, one of the eight sediment samples collected from the pond in 2009 identified very-low-levels of plant-related radionuclides (Co-60 and Cs-137). All other samples had no detectable Co-60; the Cs-137 levels were considered in the background range based on REMP results. Sampling and analysis of the pond conducted in 2010 thru 2014 have not identified any plant-related radioactivity.

Figure 2, State of Florida Sampling Locations u~:,

£Pv.,,. t - f t-vp V f-ff?

Page 5 of 7 3F1025-01 / Enclosure 11 / Page 5 of 7

191 Conclusion Due to assumption made in the HSA that did not reflect complete information, CASA (the Unit 4 and 5 coal ash pile) was classified as a MARSSIM Class 3 area. It is recognized that very-low-level radioactive liquid effluents were released to the East Settling Pond. However, the sampling and controls established for the materials transferred from the pond side walls and or specific bottom locations to CASA prevented any transfer of plant-related radioactive materials to CASA. Based on the additional information available regarding the relocation of the materials and the results of sampling and analysis, CASA is not considered an impacted area.

There is no indication that any of the radioactive sediments that may have been in the East Settling Pond were transferred to CASA. The sampling and analysis of the materials that were removed and transferred to CASA showed no detectable plant-related radioactive materials, above background. CASA should be re-classified as a Non-Impacted Area. Additional, follow-up FSS-type surveys performed at CASA identified no radioactive material distinguishable above background.

In addition, the following is an email correspondence, with accompanying image, with the Unit 4 and 5 CASA Operations Superintendent involved in the Duke Energy removal of all Coal Ash area materials from the CASA location in 2016 and 2017. This coal ash pile remediation is considered to have removed the materials that may have previously been relocated from the Settling Ponds to CASA. Any settling pond materials were removed from CASA to beneficial reuse offsite during this period.

Page 6 of 7 3F1025-01 / Enclosure 11 / Page 6 of 7

191 Ash Storage/Disposal Area (AS/DA) - CRN Ash Landfill In March of 2022, communication between the Duke Coal Ash Storage Area Environmental and their EHS SME. The Duke manager asked the EHS SME for waste and groundwater to also have a look at your characterization plan. It generally looks fine to me, but I do have some input.

The attached is a recent air photo of the landfill that I've labeled with some relevant info. I didn't add a north arrow, so please note that the image is rotated so north is to the left.

The areas of the landfill I've labeled "Northwest Disposal Area", "Reclamation Area", and "Southern Disposal Area" were essentially depleted as part of the ongoing reclamation activities for beneficial reuse sales, and any wastes currently in those locations were disposed after about 2016/7. Also the area labeled "Central Disposal Area" has been filled with several feet of filter cake from the WWTP that was placed in service in 2018/9. I understand the pond cleaning operation that is of interest to you occurred earlier ( 10 to 15 years ago??), so I doubt wastes from that project currently exist in these areas.

That really leaves the areas labeled "Northern Disposal Area" and the "Closed Slopes" to look for the waste from your project. The areas labeled "Closed Slopes" are the landfill side slopes that have reached final grades on the north, east and south end of the landfill that were capped with a geosynthetic liner, 2 ft soil cover and grass. If samples are to be collected from these areas, then we need to add some measures to protect the geosynthetic liner and repair the cap after the samples are collected. Any plant generated wastes in these areas will be under the geosynthetic liner. I'll have to provide more information if these areas cannot be avoided. Let me know. The top of the area labeled "Northern Disposal Area" is covered with vegetation, no liner. I don't foresee any issues collecting the type of samples you describe in this area. The top area can be accessed by pickup truck, but we need to limit traffic to avoid creating ruts.

Page 7 of 7 3F1025-01 / Enclosure 11 / Page 7 of 7

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