ML25288A025
| ML25288A025 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/15/2025 |
| From: | Mulkey C ADP CR3, State of FL, Dept of Environmental Protection |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25288A001 | List:
|
| References | |
| 3F1025-01 | |
| Download: ML25288A025 (1) | |
Text
ENCLOSURE 18 Crystal River Unit 3 Nuclear Generating Plant Docket Nos. 50-302 / 72-1035 Operating License DPR-72 Crystal River Unit 3 (CR3) -
Decommissioning End State Begins On Next Page lef 3F1025-01 / Enclosure 18
FLORIDA DEPARTMENT OF Environmental Protection Bob Martinez Center 2600 Blair Stone Road Tallahassee, FL 32399-2400 Ron DeSantis Governor Jeanette Nunez Lt. Governor Noah Valenstein Secretary February 15, 2019 Sent by Electronic Mail - Document Access Verification Requested Terry Hobbs General Manager Decommissioning SAFSTOR Crystal River Nuclear Plant 15760 West Power Line Street Crystal River, FL 34428 Terry.Hobbs@Duke-Energy.com RE:
Crystal River Unit 3 (CR3) - Decommissioning End State Conditions Mr. Hobbs:
This letter is in response to your December 10, 2018, request for the Florida Department of Environmental Protections (DEPs or Departments) concurrence on three specific end state conditions that will be used in Duke Energy Floridas (DEFs) development of a U.S. Nuclear Regulatory Commission (NRC) License Termination Plan (LTP) for the CR3 site. The three specific end state conditions are: 1) radioactivity dose limit for unrestricted site release; 2) excavation depth to which subsurface plant structures will be removed; and 3) reuse of clean concrete debris.
As part of preparing the LTP, DEF has indicated that it is evaluating accelerating the decontamination and dismantlement (D&D) of CR3. Some of the topics to be covered in DEFs LTP include: radiological characterization of the site; identification of dismantlement activities; plans for site remediation; detailed plans for the final radiation survey; a description of the end use of the site, if restricted; and a description of any new or significant environmental change associated with the licensee's proposed termination activities. DEF will submit the LTP to the NRC for their review and approval in accordance with federal regulations. Additionally, as part of the FDEP Conditions of Certification (COC) for the Crystal River Energy Complex, DEF is required to submit a copy of the LTP to the Department when it is filed with the NRC to allow the Department to identify any deficiencies in the plan.
You stated in your letter that the ability to establish end state conditions with certainty is critical to DEF's ability to determine the estimated cost to perform accelerated D&D, and to decide when D&D should be initiated. You also stated that it is DEFs position that 3F1025-01 / Enclosure 19 / Page 1 of 5
Terry Hobbs February 15, 2019 Page 2 of 5 the end state conditions for which you seek concurrence are either associated with an existing pre-emptive federal regulatory requirement or will be part of the LTP.
The end state conditions that have been determined by DEF to have the greatest potential to affect accurate D&D cost estimation are those for which DEP review and concurrence is requested. The three specific requests are addressed separately below.
- 1. Specific End State Condition 1: Radioactivity dose limit for unrestricted site release.
DEF requests concurrence from DEP that 25 millirem/year (distinguishable from background) is an acceptable dose limit for use in CR3 decommissioning plans for unrestricted site release.
Federal Regulations In your submittal, you cite the NRC criteria for radiological release of a site during license termination in 10 CFR 20.1402 as no greater than 25 millirem/year and As Low As Reasonably Achievable (ALARA).1 NRC Regulatory Guide 1.179 provides that the LTP should demonstrate that the dose from residual radioactivity that is distinguishable from background radiation does not exceed 25 millirem (mrem) per year, and that residual radioactivity means radioactivity in structures, materials, soils, ground water, and other media at a site resulting from activities under the licensee's control. According to your research, the NRC has not deviated from this regulation for any of the commercial nuclear power plants decommissioned to date.
State Regulations Rule 62-550.310(6)(b), Florida Administrative Code (F.A.C.), includes a Primary Drinking Water standard for man-made radionuclides of an annual dose equivalent no greater than 4 millirem/year. Although the NRC criteria of 25 millirem/year applies to the total effective dose equivalent which would include any potential potable use of groundwater, among other things, DEF has committed to ensuring that the 4 millirem/year standard will be applied as a dose limit for any potential potable use of groundwater at the CR3 site.
Department of Health Rule 64E-5, F.A.C., describes a site as acceptable for unrestricted use if the total effective dose equivalent from the residual radioactivity does not exceed 25 millirem/year including radioactivity from groundwater sources of drinking water and the residual radioactivity levels are as low as reasonably achievable. This is consistent with the NRC acceptance criteria of 25 millirem/year.
1 U.S. Nuclear Regulatory Commission, Title 10, Code of Federal Regulations, Part 20, Subpart E, Section 20.1402, "Radiological criteria for unrestricted use."
3F1025-01 / Enclosure 19 / Page 2 of 5
Terry Hobbs February 15, 2019 Page 3 of 5 Conclusion DEP concurs that 4 millirem/year is an acceptable proposed dose limit for any potential drinking water use of groundwater at the site; and that the referenced federal and state 25 millirem/year criteria is an acceptable proposed dose limit for release of the site for unrestricted use in CR3 decommissioning plans to be submitted to the NRC for review and approval.
- 2. Specific End State Condition 2: Excavation depth to which subsurface plant structures will be removed.
DEF requests concurrence from DEP that three feet below grade is an acceptable depth to which all subsurface structures would be removed in preparation for final radiological surveys.
LTPs must address planned actions to either remove or evaluate the structural components that will remain behind before final site surveys are performed. Removal of components at a site assures the 25 millirem/year dose rate will be met for the release of the site for unrestricted use. In your letter, you refer to establishment of the acceptance of excavation of structures to a depth of three feet in 1976 as an industry standard. You further state that this industry standard has historically been used both during the development of regulatory required Decommissioning Cost Estimates (DCE), and in LTPs submitted and approved by the NRC. For example, you referenced the NRCs September 28, 2018, approval that included an LTP for the Zion Nuclear Power Station, Units 1 and 2 which reflected use of the three-foot depth as the excavation standard.
As you pointed out, DEF published its intent to implement its strategy in its Post-Shutdown Decommissioning Activity Report.2 This study assumes that site structures addressed by this analysis are removed to a nominal depth of three feet below the top grade of the embankment, wherever possible. This assumption was applied to the disposition of all CR-3 facilities on the berm and, as a result, the general topography of the berm will be retained at the conclusion of site restoration.
The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can be established for erosion control."
For comparison, the quantity of fill required for closure of facilities such as landfills in Florida is typically specified as two feet of clean fill with the top six inches supportive of vegetative growth. The proposed end state condition for CR3 of excavation of subsurface structures to a three-foot depth and replacement of the 2 CR-3 to NRC letter, 3F1213-02, "Crystal River Unit 3-Post-Shutdown Decommissioning Activities Report," December 2, 2013 3F1025-01 / Enclosure 19 / Page 3 of 5
Terry Hobbs February 15, 2019 Page 4 of 5 excavated area with three feet of fill appears more stringent than landfill requirements.
Conclusion With the understanding that DEF will assure remediation of the site will be performed to meet the 25 millirem/year limit in Rule 64E-5, F.A.C., DEP concurs that the proposed industry standard of a removal depth for subsurface structures to a resulting depth of three feet below final grade is acceptable in preparation for final radiological surveys for use in CR3 decommissioning plans to be submitted to the NRC for review and approval.
- 3. Specific End State Condition 3: Reuse of clean concrete debris.
CR3 requests concurrence from DEP with its plans to segregate clean concrete debris produced during the demolition of site structures and to recycle the clean concrete debris to backfill the subsurface structures that will remain in place.
Federal Regulations According to the information provided in your letter, Supplement I of the NRC's Generic Environmental Impact Statement requires facilities to perform an analysis of acceptability of demolition debris prior to its reuse. The analysis is submitted and reviewed as part of the LTP. CR3 plans to perform the analysis required to obtain approval to segregate clean concrete debris produced during the demolition of site structures and to recycle the clean demolition debris to backfill the subsurface structures.
You note that in 2018, this practice was approved in the LTP for the Zion Nuclear Power Station in Illinois. Zion described how radiological surveys and samples would be performed to provide confidence that any plant-derived radionuclides would be detected, and agreed to assign a dose contribution to concrete debris designated for reuse, including for debris that surveys confirmed would be acceptable for an unconditional offsite release. The NRC Zion LTP Safety Evaluation Report issued in September 2018 concurred that Zion appropriately analyzed the acceptability of reuse of concrete debris with respect to assuring that any undetected contribution to the final radiological conditions of the site that might be present because of reuse of demolition debris would not impact the station's ability to meet the 25 millirem/year limit for unrestricted release.
State Regulations As identified in your letter, Rule 62-701.730(17), F.A.C., includes a provision for recycling or reuse of demolition debris, via onsite disposal, on the property where it is generated. That is, this provision would allow reuse of non-contaminated concrete 3F1025-01 / Enclosure 19 / Page 4 of 5
Terry Hobbs February 15, 2019 Page 5 of 5 debris as structural fill for remaining subsurface structures. It is your understanding, based on discussions with DEP regulatory staff, that disposal of concrete, meeting the definition of "clean debris" contained in Rule 62-701.200, F.A.C., on the property where it was generated is allowable pursuant to this rule with no further required permitting. As defined in Rule 62-701.200(15), F.A.C., Clean debris means:
any solid waste that is virtually inert, is not a pollution threat to ground water or surface waters, is not a fire hazard, and is likely to retain its physical and chemical structure under expected conditions of disposal or use. The term includes brick, glass, ceramics, and uncontaminated concrete including embedded pipe or steel.
You stated, It is DEF's position that so long as radiological surveys (i.e. inspections) are performed to verify concrete is not contaminated and would be acceptable for unconditional offsite release to any construction and debris landfill in accordance with federal guidelines, that the debris produced from demolition of the concrete would meet state requirements to be considered uncontaminated concrete and therefore clean debris if no other contaminants of concern are present.
Conclusion With the understanding that DEF will perform radiological surveys and assure that the debris produced from demolition of the concrete would meet state requirements to be considered clean debris as defined in Rule 62-701.200(15), F.A.C., DEP concurs with DEFs plans to segregate clean concrete debris produced during the demolition of site structures and to recycle the clean demolition debris to backfill the subsurface structures that will remain in place. Please note that the cited provision under Rule 62-701.730(17), F.A.C., allowing clean debris such as non-contaminated concrete to be disposed of on the property where it is generated, also specifies that the final cover shall consist of a 24-inch-thick soil layer, as well as other requirements such as associated grading and side slope requirements.
If you have questions regarding this feedback please contact me at (850) 717-9110.
Sincerely, Cindy Mulkey, Administrator Siting Coordination Office CC by email:
Paula Leverett Cobb, Duke John A. Coates, DEP Cindy Mulkey Digitally signed by Cindy Mulkey Date: 2019.02.15 15:05:39
-05'00' 3F1025-01 / Enclosure 19 / Page 5 of 5