3F0226-02, Response to License Termination Plan Request for Supplemental Information

Response to License Termination Plan Request for Supplemental Information

ML26056A059
Person / Time
Site:	Crystal River   (DPR-072)
Issue date:	02/25/2026
From:	Reid B ADP CR3
To:	Office of Nuclear Reactor Regulation, Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
3F0226-02
Download: ML26056A059 (0)

Text

ADP CR3, LLC CR3 Decommissioning 15760 West Power Line Street l Crystal River, FL 34428 Page 1 of 2 Billy Reid, Site Executive Cellphone: 865-384-6789 Email: breid@northstar.com 3F0226-02 10 CFR 50.90 February 25, 2026 10 CFR 50.82 (a)(9)

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Docket Nos. 50-302 & 72-1035, Operating License Number DPR-72 Crystal River Unit 3 Nuclear Power Station

Subject:

Response to CRYSTAL RIVER UNIT 3 LICENSE TERMINATION PLAN REQUEST FOR SUPPLEMENTAL INFORMATION

References:

1. Letter from ADP CR3 (B. Reid) to USNRC (Document Control Desk), License Amendment Request 263, Addition of License Condition 2.C.21, License Termination Plan, dated October 15, 2025 (ML25288A001 Package).

2. Letter from ADP CR3 (B. Reid) to USNRC (Document Control Desk), Revision to Crystal River Unit 3 License Termination Plan, dated December 11, 2025 (ML25345A212 Package).

3. Letter from NRC (Chris Allen) to ADP CR3, Crystal River Unit 3 License Termination Plan Request for Supplemental Information, dated January 30, 2026 (EPID L-2025-LLA-0173) (ML26021A159).

Dear Commissioners and Staff,

By letter dated October 15, 2025 (Reference 1), and supplemented by letter dated December 11, 2025 (Reference 2), ADP CR3, LLC (ADP CR3) submitted a License Amendment Request (LAR),

in accordance with 10 CFR 50.90 and 10 CFR 50.82(a)(9), to add a license condition 2.C.21, which approves the License Termination Plan (LTP) and adds a license condition that establishes the criteria for determining when changes to the LTP require prior NRC approval.

On January 30, 2026 (Reference 3) the NRC provided ADP CR3 with a request for supplemental information to enable the staff to complete its review and make an independent assessment regarding the acceptability of the proposed amendment. The enclosure to this letter provides the responses to the requests for supplemental information.

There are no new regulatory commitments contained within this letter.

Page 2 of 2 In accordance with 10 CFR 50.91(b), ADP CR3 is providing a copy of this submittal to the State of Florida.

If you wish to discuss the information in the enclosures, please contact Mr. John Jernigan at (352) 342-0792.

I state under penalty of perjury that the foregoing is true and correct. Executed on February 25, 2026.

Sincerely, Billy Reid, Site Executive

Enclosure:

CR3 Responses to NRCs Supplemental Information Requests cc:

Regional Administrator, Region 1 NMSS Project Manager State of Florida

ENCLOSURE Crystal River Unit 3 Nuclear Generating Plant Docket Nos. 50-302 / 72-1035 Operating License DPR-72 CR3 Responses to NRCs Supplemental Information Requests Begins On Next Page 3F0226-02 / Enclosure lef

CR3 RESPONSES TO NRCs SUPPLEMENTAL INFORMATION REQUESTS Technical Review Sampling Supplemental Information Requests

1. LTP Section 2.11.1.1, CRRB - Crystal River Reactor Building, stated that a total of 13 core samples were collected on the 95-foot elevation of the Reactor Building floor and submitted to GEL for analysis of the full-suite of radiological parameters and that only selected samples were used for averaging and determining fractional abundances.

GELs analytical results for the selected samples were provided in LTP Table 2-10. LTP Table 2-10 only provided the results for five samples which is insufficient to derive relative fractions, identify insignificant contributors, and establish surrogate ratios.

1. 1: Request: Provide the results of all thirteen core samples collected in the Reactor Building (RB) during the characterization survey. Also, describe how the insignificant radionuclides and fractional abundances will be determined/verified at the time of final status survey. This would be a concern for survey units immediately adjacent to areas with differing radionuclides of concern or fractional abundances which may have inadvertently spread contamination into the adjacent survey units during remediation activities.

1. 1 Response: The GEL Reports for the 13 RB samples will be provided via Kiteworks. For three sampling locations (e.g., RB-C-002, RB-C-008, and RB-C-009), the core samples were segmented by depth with separate analysis. To illustrate, for RB-C-008, the first reported results for the sample represent the top 10 mm; the second reported results represent the next 0.5-inch depth; and the third reported results are for the next 0.5-inch depth. Generally, radioactivity levels decreased with depth. As reported in LTP Table 2-10, core samples with multiple analyses by depth were averaged to be representative of the location for deriving fractional abundances.

Details were also requested for how the insignificant radionuclides and fractional abundances will be determined/verified at the time of final status survey. In general, the radionuclide distribution is reevaluated when FSS surveys (samples or measurements) exceed 75% of the applicable ALARA DCGL. As discussed in LTP Section 6.4.1 (second bullet), During the FSS, if samples collected in the SU at the pre-selected locations exceed 75 percent of the DCGL investigation level, the FSS engineer will be notified to determine the investigation actions. It further states (third bullet), As more analytical information is collected, the radionuclide distribution and correlated radionuclides (if surrogates are used, see LTP Chapter 5, Section 5.2.9) will be modified, as necessary, using relevant analytical results to ensure a conservative correlation of sample results to activity levels as used for the compliance assessment (Equations 6-7 and 6-8, above).

The intent is that should FSS samples or measurements exceed 75% of the applicable ALARA DCGL, samples will be collected with analysis for all ROCs. For the Reactor Building the number and type samples will depend on the end state. If the steel liner is the End State, then smears will be collected from identified elevated areas, composited and analyzed for all ROC.

3F0226-02 / Enclosure / Page 1 of 10

If end state is concrete, concrete core samples will be collected. With levels exceeding 75%

ALARA DGCL, a minimum of 2 samples will be collected for all ROC analysis. The radionuclide distribution will be reevaluated considering the results and included in the determination of both the dose significant ROC as well as an overall compliance assessment. The application of the ALARA DCGLs for the RB foundation and walls are the Action Levels as derived for the Less Likely but Plausible (LLBP) scenario in LTP Section 6.3.5.4.

The approach described above is considered applicable for all survey units and FSSs.

2. Enclosures 7, CHAR-09 Impacted Open Land Area At-Depth Survey and Sampling, and 8 Historical Site Assessment for Crystal River 3, of the LTP describe two events in 1979 and 1980 in which core flood water was cross-tied to the nitrogen system, contaminating the Nitrogen and Hydrogen Stage Area. Enclosure 8 identifies that the affected nitrogen piping was subsequently abandoned in place. Enclosure 8 also documented a July 2010 release of radioactive water outside the Radiologically Controlled Area. As noted in LTP Section 2.7.4.7, NORB - North of the Reactor Building Survey Units, a contaminated nitrogen line was identified approximately 5 feet below ground surface on the northeast berm outside the Turbine Building. Soil sampling detected Co-60 and Cs-137.

Regarding the events in 1979, 1980 and 2010, Enclosures 7 and 8 do not discuss either remediation efforts or sampling activities. LTP Section 2.7.4.7 identifies that remediation occurred when the contaminated nitrogen line was identified; however, no further details are provided. Enclosure 7 indicates that the maximum subsurface sampling depth is 24 inches.

NUREG-1757, Volume 2, Revision 2, Section 3.6, recommends that the depth of residual radioactivity in surface and subsurface soils be determined based on characterization survey results. In instances involving spills or leaks, where migration of residual radioactivity is possible, subsurface sampling to a depth consistent with the extent of the release provides assurance of adequate characterization.

1. 2 Request: Provide the following for the contamination incidents identified above:

(a) results for surveys conducted during and after the incidents including information on radionuclides of concern (ROCs) and hard to detect (HTD) radionuclide analysis, and (b) justification for limiting subsurface sampling depths to 24 inches when contaminated pipes are deeper than 24 inches.

1. 2 Response:

a) The requested surveys (measurements and soil samples) were conducted under the operational Radiation Protection Program and, therefore, did not include sample analyses for hard-to-detects (HTDs). Surveys performed are not considered adequate to support a Final Status Survey and compliance assessment. The impacted areas were remediated for ALARA purposes following the events under the operational RP program.

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The results of the operational remediation will not be used for FSS. The effectiveness of remediation will be verified during the required FSS.

Both areas for the nitrogen line leak and the Nitrogen and Hydrogen Storage Area are Class 1 Survey Units for Final Status Surveys. See LTP Sections 2.7.4.7 and 2.7.4.8.

As such, they will be 100% scanned along with the nominal 15 to 20 samples collected for analysis. Should either the scanning or samples exceed 75% of the applicable ALARA DCGLs, samples will be collected from area(s) exceeding 75% ALARA DCGLs and analyzed for all ROCs; radionuclide distribution and dose significant ROCs reevaluated; and a final dose compliance reflecting any changes.

b) Actions that are taken to address potential for subsurface contamination are described in LTP Section 6.4.1, where it states: If surveys identify residual activity below the top 6 inches of soil, the area will be assessed for remediation. The ALARA Subsurface DCGLV will be used to perform the compliance assessment, as described in Section 6.4.2, will be followed.

To clarify the intended actions, the following statement will be added to the specified actions: Any measurement greater than 75% ALARA Surface Soil DCGLW will be investigated for subsurface contamination. Subsurface soils will be sampled in 1-meter increments and continue until residual levels show declining concentration levels and below 25% of the ALARA Subsurface Soil DCGLVs.

The contaminated nitrogen line that is identified as approximately 5 feet below grade is scheduled for further characterization (see LTP Table 2-29) with planned removal. A visual inspection of the pipe will be attempted in order to determine the condition of the interior of the pipe. The removal of the line is from the east side of the Turbine building up to where it underlies the ISFSI and from the former hydrogen / nitrogen storage area heading north up to a safe distance from the railroad track. Radiological assessments during and following excavation / removal of this line are covered in LTP Sections 5.2.7 and 5.3.1.4, addresses surveys performed during and following excavation. An FSS will be performed on the excavated area prior to any backfill, thereby eliminating any concern about unevaluated residual subsurface contamination from buried pipes, in particular the nitrogen line.

Derived Concentration Guideline Levels (DCGLs) Supplemental Information Requests

3. LTP Table 6-15 presented the derived concentration guideline levels (DCGLs) in dpm/100 cm² for a Qbucket across a range of pipe diameters. Similarly, Table 6-14, BOP Building ALARA Surface Scan DCGLs for Various Pipe Diameters, provides corresponding values for the Balance of Plant (BOP). Section 6.3.5.7, Applying LLBP Scenario for Embedded or Buried Piping included a sample calculation for determining the dpm value for a Qbucket in the BOP based on an initial concentration of 9.6 pCi/g. The volumetric concentration DCGL for the Reactor Building is 9.5 pCi/g as specified in LTP Sections 5.2.6 and 6.3.5.4. This concentration would yield lower DCGL values in dpm/100 cm2 than those reflected in Table 6-13.

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1. 3 Request: Provide the spreadsheet or calculations for the derivation of the piping ALARA DCGLs found in Table 6-15, RB ALARA Pipe Surface Scan DCGLs for Various Pipe Diameters. to assist NRC staff in verifying the piping DCGLs.

1. 3 Response: The referenced Table 6-15 in LTP Rev. 4 is titled: Reactor Building and BOP Action Level Allowance for Various Pipe Diameters. The LTP Rev. 3 included separate tables for the RB and BOP (Tables 6-13 and 6-14, respectively). With Rev. 4, the radionuclide fractional abundances for the RB and BOP became the same for the buried pipe modeling at the second significant figure. Therefore, the Action Levels, in units of dpm/100 cm2, were combined into a single table. As stated in LTP Section 6.3.5.7, The Gross DCGL is the same for the RB and BOD at 19.1 pCi/g; therefore, the derived Action Levels are the same.

The EXCEL spreadsheet to support these calculations will be provided via Kiteworks.

4. Pursuant to 40 CFR 192, soils associated with the top 15 cm are considered surface soils while subsurface soils are greater than 15 below the surface. This definition is further supported by the definition of surface soil and the discussion of surveys in appendix G to NUREG-1757, volume 2. Appendix L and table 5.2 of NUREG-1757, volume 2, revision 2 extend the depth down to 30 cm. MARSSIM guidance in NUREG-1575 also defines surface soils to be associated with the top 15 cm.

The NRC/EPA MOU, which was established to facilitate decision-making in the decommissioning of NRC-licensed facilities, provides separate soil trigger values for residential and industrial/commercial exposure scenarios. As noted in table 6-2 of the LTP, Crystal River proposes to consider the industrial/commercial values when determining the ALARA DCGL values used for evaluating compliance.

Section 6.3.2 and Table 6-2 of the Crystal River LTP define ALARA DCGLs as the smallest value when comparing site-specific DCGLs calculated using RESRAD-Onsite, version 7.2, and a resident farmer scenario with the NRC/EPA MOU Industrial/Commercial Soil Concentration values. In the case of surface soil DCGLs, no basis is provided for comparing RESRAD-calculated resident farmer DCGLs with NRC/EPA MOU Industrial/Commercial Soil Concentration values instead of NRC/EPA MOU Residential Soil Concentration values, which are associated with an exposure scenario similar to the resident farmer. In addition, no basis is provided for the use of MOU Soil Concentration values, which are intended to address soil contamination on the surface, with subsurface residential farmer DCGLs calculated using RESRAD-Onsite, version 7.2, and a soil depth down to 1 m (i.e., depths greater than what is considered to be the surface).

1. 4 Request: Provide the following information:

a) The basis for using NRC/EPA MOU industrial trigger values as DCGL values for a resident farmer exposure scenario, b) The basis for using NRC/EPA MOU surface soil trigger values as subsurface soil (0

- 1 m) DCGL values, 3F0226-02 / Enclosure / Page 4 of 10

c) ADP CR3 Procedure NS-FSS-11, Split/Recount Sample Assessment for Final Status Survey, and d) Electronic RESRAD-Onsite files used to calculate DCGLs and area factors."

1. 4 Response:

4. The issue with the use of the industrial trigger values is identified in the RSI as: In the case of surface soil DCGLs, no basis is provided for comparing RESRAD-calculated resident farmer DCGLs with NRC/EPA MOU Industrial/Commercial Soil Concentration values instead of NRC/EPA MOU Residential Soil Concentration values, which are associated with an exposure scenario similar to the resident farmer. ADP-CR3 selection of the industrial trigger values is based on the fact that the Crystal River site is designated an industrial, commercial zoning, collocated with a two-unit coal fired generating facility. The Site-Specific DCGLs are based on the resident farmer scenario sole due to a contractual agreement between ADP-CR3 and Duke Energy, the owner of the site property following license termination. Except for this contractual agreement, ADP-CR3 could have selected the industrial exposure scenario for its Site-Specific DCGL development.

5. Additionally, NRC expressed concern about the application to subsurface soils, stating:

In addition, no basis is provided for the use of MOU Soil Concentration values, which are intended to address soil contamination on the surface, with subsurface residential farmer DCGLs calculated using RESRAD-Onsite, version 7.2, and a soil depth down to 1 m (i.e., depths greater than what is considered to be the surface). The MOU Soil Concentrations were applied to the subsurface soil comparison due to the absence of any other soil values (e.g., subsurface soil) in the MOU. The MOU does not distinguish between surface and subsurface soils, only presenting soil concentrations.

Regardless, these two concerns, a) related to industrial versus residential trigger values and b) concerning use of surface versus subsurface, have no bearing on the final dose assessment for compliance with 10 CFR 20.1402. As stated in Section 6.2: In summary, the ALARA DCGLs will be used by FSS technicians for FSS field measurements in the SUs, and the FSS Engineer will compare the FSS measurements to the sum-of-fractions to determine compliance with acceptance criteria. The site-specific Resident Farmer DCGLs will be used by the FSS Engineer to determine the final site dose.

6. Provided via Kiteworks

7. Provided via Kiteworks Environmental Review Regulatory Basis:

Pursuant to 10 CFR §51.53(d) and 10 CFR §50.82(a)(9)(ii)(G), the LTP must include a description of any new information or significant environmental change associated with the 3F0226-02 / Enclosure / Page 5 of 10

licensee's proposed termination activities to reflect any new information or significant environmental change associated with the applicant's proposed decommissioning activities.

Environmental Assessment Supplemental Information Request Section 8.1.1 states It should be noted that in July 2024, following review of previous versions of this LTP, along with the submittal of additional information per request, the NRC issued an Environmental Assessment for the License Termination Plan for Crystal River Unit 3 in Citrus County, Florida (EA; [8-7]). Based on the EA, the NRC issued a Finding of No Significant Impact (FONSI) as published in the Federal Register [8-8]. With this finding, the following sections have not been updated and represent the accepted data that supported the FONSI.

The Environmental Assessment issued by the NRC staff in July 2024 may not be applicable to this licensing action. For example, information on Federally listed species is updated approximately every thirty days. Therefore, the NRC staff needs to confirm that the findings in the July 2024 Environmental Assessment is still valid.

Request: Provide supplemental information, if necessary, including but not limited to information about project completion dates and dose estimates through those dates, the geographic area of the evaluation for each resource area, and federally listed species that may occur on the site.

Response

The conclusions from Chapter 8 of the LTP document an assessment of the environmental effects of decommissioning the CR3 site. The assessment had determined that the environmental effects from decommissioning CR3 are being minimized to the extent practicable, and no adverse effects are outside the bounds of those described in the Final Generic Environmental Impact Statement (Final GEIS). Chapter 8 provides supplemental information to the Environmental Report and the Revised Post-Shutdown Decommissioning Activities Report (PSDAR), which ultimately led to the NRC issuing a FONSI as documented in Federal Register Vol. 89 No. 137, dated July 17, 2014, Docket NRC-2024-0124.

In response to the Request for Supplemental Information (RSI) provided above for reference, this document updates the LTP to confirm that the original no significant impact conclusions remain valid. This supplement provides updated site activity data for areas for each resource, and an assessment of federally listed species that may occur at the site.

The fundamental environmental conclusions published in both the Environmental Assessment (EA) published in July 2024 and LTP Revision 4 published in December 2025 remain valid. The most significant change would be the license area, as with approval of the Partial Site Release, the license area has been reduced from 4,738 to 265 acres. Additionally, the project is now scheduled to be completed in 2027.

An evaluation of available information confirms that there have been no significant changes to the following resource areas since the issuance of the EA in July 2024:

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Biological Resources: Threatened and endangered species, terrestrial and aquatic ecology (beyond the operational area), and general site biota.

To document any changes to protected taxa, the U.S. Fish and Wildlife Information for Planning and Consultation (IPaC) database was reviewed in January 2026 for federal and state-listed species. This review confirmed that no additional species have been listed and no additional critical habitats have been impacted. Furthermore, the total license area has been significantly reduced from 4,738 to 265 acres, thereby minimizing potential habitat overlap and reducing the likelihood of species present within the project boundaries.

Socioeconomics and Land Use: Environmental justice, offsite land use, and historic/cultural resources.

There have been no significant shifts in the socioeconomic demographics of Crystal River or its neighboring communities. Likewise, local and regional land use patterns have remained stable since 2024. Consequently, the 2020 Census remains the most accurate and appropriate dataset for this evaluation. Community impacts regarding traffic also remain unchanged, as the majority of waste continues to be transported via rail, minimizing the burden on local roadways.

Physical Environment: Site geography, demography, geology, seismology, hydrology, and hydrogeology.

Aside from minor alterations to shallow surface soils resulting from decommissioning and localized remediation, there have been no significant changes to the site's geography, demography, geology, seismology, hydrology, or hydrogeology. The fundamental physical and environmental characteristics of the area remain consistent with previous assessments.

Archaeological, Aesthetic issues, Noice, and Historical Significance:

There have been no changes to the site or project scope that would affect its archaeological significance or necessitate further consultation with the State Historic Preservation Office (SHPO) or Tribal Nations. Furthermore, impacts related to aesthetics and noise remain unchanged and continue to be bounded by the analysis provided in the Final GEIS.

Climate Change: The affected environment and climate change projections remain relatively unchanged from 2024.

Environmental Effects of Decommissioning: Decommissioning is still expected to have significant beneficial impacts, including eliminating the risks associated with a commercial nuclear facility.

The adverse effects associated with decommissioning include routine occupational radiation exposure and the commitment of land off site for radioactive waste disposal. As discussed in the FGEIS, radiation exposure to the public is small, even when accidental airborne radioactive releases are considered. The low-probability, worst-case exposure to an individual from an accident involving a truck transporting radioactive waste to a disposal facility continues to be small.

Cumulative Impacts: The cumulative impacts from regional projects have decreased since the previous reporting period. This reduction is attributed to the completion of area roadway infrastructure improvement projects, as well as the completion of the Crystal River Mall demolition.

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The Findings of No Significant Impact (FONSI) in the EA is still relevant and applicable to the LTP.

CLARIFICATION INFORMATION REQUESTS

8. Section 5.2.4.2, Specific Structural Material Backgrounds indicated that ambient background for concrete may be determined within the survey unit by shielding the face of the detector or taking a measurement with the detector held in the air pointed away from the concrete surface. Describe what is meant by shielding the face of the detector.

Response: Shielding the face of the detector is a plastic protective covering, typically the one that is provided with the detector. This shielding eliminates any detector response from the ambient beta and alpha activity while the resulting response will reflect that associated with the ambient gamma component. This method for determining the ambient background is a routine industry practice, since the detector signal of concern is the beta and alpha response.

9. Section 2.10.1.6, Gamma Surface Scan states Sodium iodide (NaI) scintillation detectors (e.g., Ludlum Model 44-10 and 43-93) were used for these scans. However, the Ludlum Model 43-93 is an alpha/beta scintillation detector. Confirm the type of detector used for the gamma scans discussed in Section 2.10.1.6.

Response: The reference to Ludlum Model 43-93 is incorrect and will be removed during a future update to the LTP.

10. Several sections of the LTP (Section 5.2.11.4, Upper Bound of the Gray Region, Section 5.4, Final Status Survey Data Assessment) reference operational DCGLs.

Clarify whether the Operational DCGL is the ALARA DCGL. Additionally, Section 5.4.3.5, Investigation Levels states, For CR3, the main IL is the Operational DCGL that is 75% of the DCGLw. Elsewhere in the LTP, the IL is 75% of the DCGLw or 75%

of the ALARA DCGL. Clarify which DCGL is used as a point of comparison.

Response: The use of the term Operational DCGL is intended to reflect where the ALARA DCGLs have been converted to operational values, reflecting instrument response to the established dose significant radionuclide distribution. Its intent is to reflect a operational application consistent with that described in MARSSIM, Section with the addition of instrument response.

The reference to Operational DCGL and DCGLW in Section 5.4.3.5 is meant to reflect the applicable ALARA DCGL, where operational values are established for use in correlating instrument response to the established ALARA DCGLs, considering the dose significant radionuclides.

CR3 recognize the potential confusion that use of the terms DCGLW and Operational DCGL might cause. During a future update to the LTP, the term DCGLW will be replaced with ALARA DCGLW. The term Operational DCGL will be eliminated or replaced with more descriptive wording, such as operational value equivalent to the ALARA DCGL.

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11. Section 5.3.1.8, Embedded Piping and Penetrations of the LTP states, HTD ROCs are inferred to the applicable gamma radionuclide concentration to derive a concentration for each ROC for each measurement taken. Clarify whether surrogate ratios are being applied for piping and to which piping these may apply.

Response: The method for correlating the presence of HTD ROC with the gamma emitting ROCs as measured by the gamma sensitive pipe detectors is described in Attachment 13, Technical Support Document, Guideline for Embedded and Buried Pipe Detector Calibration and Usage. A surrogate ratio is not applied, for example such as C-14 to Cs-137, is not applied. Rather as described in the Technical Support Document, a pipe detector response is developed that is based on the established fractional abundance for the dose significant ROCs, separately for the Reactor Building and Balance of Plant.

12. Section 5.3.1.6, Pavement Covered Areas of the LTP explained that paved surfaces will be incorporated into the larger open land survey units in which they reside. Scanning and sampling of the pavement will be conducted. Clarify where soil samples beneath the pavement will be collected and analyzed.

Response: For the most part, all pavement and concrete over land surfaces are to be removed. For the few remaining areas, there is no historical knowledge of potential for subsurface radiological contamination. Therefore, no sampling of soil beneath the paved surfaces is planned unless scan or surface sample measurement indicate levels above 75%

of the ALARA DGCL. Additionally, soil sampling beneath a paved surface will be performed if any scan or sample measurement in adjacent unpaved areas within the same survey unit indicate levels above the 75% ALARA DCGL criterion.

13. Am-241 and Pu-239 are included in the full suite of radionuclides and are included as ROCs in Table 5-6, Ludlum 43-93 or 43-147 Weighted Efficiency for ROCs for Reactor Building. However, they have been excluded from Table 5-7, Ludlum 43-93 or 43-147 Weighted Efficiency for ROCs for BOP. Clarify if excluding Am-241 and Pu-239 from Table 5-7 is an oversight and reconcile Tables 5-6 and 5-7 as necessary.

Response: Table 5-7 will be modified to include Am-241 and Pu-239 for completeness during a future LTP revision. Including Am-241 and Pu-239 will not alter the calculated total efficiency due to very-low abundance and no instrument detection as shown in Table 5-6.

14. Section 2.13.6 of the LTP provided a description of the ongoing groundwater monitoring program. Please confirm if the program will continue as described or if it has or will be modified in accordance with the needs of the LTP. The response may consider the data quality objectives applied for collection of that data and include information on the interpretation and reporting of the data.

Response: The following sentences will be added into Section 2.13.7 of the LTP during a future revision. "Ongoing groundwater monitoring will continue as described in the REMP.

Wells CR3-1 thru CR3-10 will be sampled semi-annually and analyzed for tritium and gamma-emitting radionuclides. Annually, monitoring wells CR3-4, CR3-5, CR3-6D, and CR3-7 will be analyzed for all ROCs. This sampling and analysis will continue for two 3F0226-02 / Enclosure / Page 9 of 10

sampling cycles following completion of final decommissioning activity that involves soil disturbance activities from within Class 1 and 2 Survey Units."

EDITORIAL CHANGE REQUESTS

15. Section 2.11.2, Results of Open Land Surveys indicates the characterization details from CHAR-01 are included in Enclosure 3 of the LTP rather than Enclosure 14.

Response: Reference to Enclosure 3 will be changed to Enclosure 14.

16. Section 2.11.2, Results of Open Land Surveys indicates the CHAR-09 report is found in Enclosure 10 of the LTP rather than Enclosure 7.

Response: Reference to Enclosure 10 will be changed to Enclosure 7.

17. The Figure 3-1 title is General Site Conditions - August 2025 which is inconsistent with the text in Section 3.2, Completed Decommissioning Activities and Tasks. The text in Section 3.2 states that Figure 3-1 shows the general state of decommissioning at CR3 as of February 2025. Please reconcile the figure title with the text.

Response: The referenced dates will be checked and made consistent between the text and figure.

18. The units in the efficiency column of Table 5-9, NaI Detector Scan Efficiencies and Table 10, NaI Detector Static Efficiencies is inconsistent with the information in 6. Please reconcile Tables 5-9 and 5-10 with the text in Enclosure 16.

Response: The units for efficiency in Tables 5-9 and 5-10 will be changed to (cpm/pCi/g) for consistency with Enclosure 16.

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