ML18171A218

Letter to the Ohio State Historic Preservation Officer Regarding Centrus Lead Cascade Decommissioning Plan Conclusion of Section 106

ML18171A218
Person / Time
Site:	07007003
Issue date:	07/16/2018
From:	Roman C Environmental Review Branch
To:	Logan B Ohio History Connection
Trefethen J
References
Download: ML18171A218 (4)

Text

B. Log UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 16, 2018 Mr. Burt Logan, Executive Director and Chief Executive Officer State Historic Preservation Office Ohio History Connection 800 E 17th Ave.

Columbus, OH 43211

SUBJECT:

CONCLUSION OF SECTION 106 CONSULTATION FOR THE AMERICAN CENTRIFUGE OPERATING LLC REQUEST TO REVIEW AND APPROVE THE DECOMMISSIONING PLAN FOR THE LEAD CASCADE FACILITY (DOCKET NUMBER: 70-7003)

Dear Mr. Logan:

The U.S. Nuclear Regulatory Commission (NRC) has been working with the Ohio State Historic Preservation Office (OH SHPO) on the National Historic Preservation Act (NHPA) Section 106 consultation related to the American Centrifuge Operating, LLC (ACO) Lead Cascade Facility (LCF) Decommissioning Plan (DP). In recent discussions with the Advisory Council on Historic Preservation (ACHP), the NRC has determined that NRCs approval of ACOs DP constitutes a federal undertaking. However, the activities described in the DP do not have the potential to cause effects on historic properties, if any are present. Thus, in accordance with Title 36 of the Code of Federal Regulations (36 CFR) 800.3(a)(1), the NRC has concluded that it has no further obligations under Section 106 of the NHPA.

This letter closes out the administrative record for the NRCs Section 106 consultation conducted for this undertaking. The following provides a brief history of the LCF and a summary of the Section 106 consultations to date related to the LCF.

Licensing Summary Located in Pike County, Ohio, the LCF operated between August 2006 and March 2016 under NRC License SNM-7003. The LCFs purpose was to provide reliability, performance, cost and other data on centrifuge designs for use in the decision whether to construct and operate a commercial uranium enrichment plant, commonly referred to as the American Centrifuge Plant (ACP)1. The LCF is contained within buildings leased from the U.S. Department of Energy (DOE) on a site owned by the DOE, known as the Portsmouth Gaseous Diffusion Plant reservation (PORTS).

By letter dated March 2, 2016, ACO notified the NRC, of the decision to permanently cease operation of the LCF, and to terminate NRC License SNM-7003 following decontamination and decommissioning activities (Agencywide Documents Access and Management System (ADAMS) Accession Number ML16074A405). Since then, under the conditions in NRC License SNM-7003, ACO has (1) removed all radioactive material from the centrifuges and associated piping, (2) disconnected the centrifuges from their mounts, and (3) packaged, transported and disposed of the centrifuges and equipment at the DOEs Nevada National Security Site.

1 Although licensed, the ACP has not been constructed.

B. Logan 2 ACO completed this work in December 2017. The NRC documented its environmental review of the disposition of these materials in an Environmental Assessment issued in June 2017(ADAMS Accession Number ML17153A093).

By letter dated January 5, 2018, ACO submitted to NRC the LCF DP (ADAMS Package Number ML18025B285). The DP includes ACOs proposed Final Status Survey (FSS) design. ACO is seeking to meet the unrestricted release criteria in Title 10 of the Code of Federal Regulations Part 20.1402, with the purpose of the FSS to ensure that residual radiological contamination is below these criteria. ACOs planned radiological survey activities under the proposed FSS would occur within the LCF leased buildings, and no new construction or land disturbance is planned or expected.

NHPA Section 106 Consultation Summary By letter dated August 2, 2002, USEC Inc. (currently operating as ACO) consulted with the OH SHPO (ADAMS Accession Number ML18194A176). In this letter, USEC Inc. found that the installation and operation of the LCF would not have an adverse effect on historical resources and would not impact the historical integrity of the PORTS site. In a response letter dated October 15, 2002, the OH SHPO concurred with no adverse effect on historic properties as the buildings for the LCF are not integral to the Portsmouth Gaseous Diffusion Plant operation.

As part of the decommissioning process for the PORTS facility, the DOE conducted an NHPA Section 110 survey of architectural properties at PORTS. An additional summary report of cultural resource surveys was also developed for PORTS. A DOE record of decision (ROD) identified 33 of the 196 buildings at the PORTS site to be historic properties. The ROD indicated that the historic properties are directly related to the PORTS Cold War Mission and are eligible for inclusion in the National Register of Historic Places. Mitigation measure were identified and are being implemented by DOE to address impacts to the 33 buildings. None of the 33 buildings identified are associated with the LCF, and the proposed LCF DP activities have not had an adverse effect on any of the 33 buildings.

For the 2017 Environmental Assessment regarding disposition of the LCF materials at Nevada National Security Site, the NRC consulted with the OH SHPO. The OH SHPO responded by letter dated May 8, 2017, stating that a finding of No Adverse Effect for the proposed action is appropriate (ADAMS Accession Number ML17144A176).

For the present undertaking, the NRC staff consulted with the OH SHPO via letter dated April 9, 2018 (ADAMS Accession Number ML18078B230). In that consultation letter, the NRC staff identified the activities involved in the LCF DP and noted that there were no ground-breaking activities and the LCF buildings would remain intact after completion of the FSS. The OH SHPOs office replied by letter dated May 16, 2018 (ADAMS Accession Number ML18155A298). In the reply, the OH SHPO indicated that it could not concur with the NRCs determination of no adverse effects. The OH SHPO also recommended that NRC contact the ACHP. On June 11, 2018, a conference call was held between the OH SHPO, the ACHP and the NRC to discuss the concerns expressed in the OH SHPOs May 16, 2018 letter. During this call, the ACHP expressed its understanding that the proposed activity was the type of activity that falls under 36 CFR Subsection 800.3(a)(1) and has no potential to cause effect to the historic properties on the PORTS site, and also that the NRCs responsibilities under Section 106 are fulfilled. The NRC agrees with the ACHP and is therefore closing out the consultation with the OH SHPO on this action.

B. Logan 3 If you have any questions about this matter, please contact Ms. Jean Trefethen of my staff.

Ms. Trefethen can be reached by telephone at (301) 415-0867 or via e-mail at Jean.Trefethen@nrc.gov.

Sincerely,

/RA JMuir-Quintero for/

Cinthya I. Román, Chief Environmental Review Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards

ML18171A218 *via email OFC FCSE/ERB FCSE/ERB OGC FCSE/ERB NAME JTrefethen AWalker-Smith GHenderson JMuir-Quintero for CRomán DATE 07/8/2018 07/13/2018 07/13/2018 07/16/2018