LIC-18-0030, Request for Partial Site Release Phase 2

Request for Partial Site Release Phase 2

ML18316A036
Person / Time
Site:	Fort Calhoun
Issue date:	11/12/2018
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LIC-18-0030
Download: ML18316A036 (18)

Text

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Omaha Public Power District 10 CFR 50.83(b)

November 12, 2018 LIC-18-0030 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054

Subject:

Fort Calhoun Station, Unit 1 Request for Partial Site Release Phase 2

Reference:

1. Letter from OPPD (M. J. Fisher) to USN RC (Document Control Desk), "Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report," dated March 30, 2017 (LIC-17-0033)(ML17089A759)

Omaha Public Power District (OPPD), the licensee for Fort Calhoun Station (FCS), is requesting approval to remove a portion of the site from the Part 50 License (License No.

DPR-40). Specifically OPPD intends to remove/release two non-impacted survey units north and east of FCS from its Part 50 license in accordance with 10 CFR 50.83(b),

"Release of part of a power reactor facility or site for unrestricted use." This activity is described in LIC-17-0033, Fort Calhoun Station, Unit No. 1, FCS Post Shutdown Decommissioning Activities Report (Reference 1).

Enclosure 1, "Supporting Information for Request for Partial Site Release Phase 2,"

provides the supporting information for a partial release of the site for unrestricted use before receiving approval of the License Termination Plan (LTP) in accordance with the provisions of 10 CFR 50.83(b ). Enclosure 1 includes a description of the property and evaluation of the effect of releasing this property. The evaluation concludes that all applicable regulatory requirements will continue to be met.

Enclosure 2 is a Computer Disk containing the non-NRC references from Enclosure 1.

These references support the summary and conclusions described in Enclosure 1.

There are no regulatory commitments to the NRC made in this letter.

OPPD requests NRC approval of this request by May 31, 2019.

U.S. Nuclear Regulatory Commissioning LI C-18-0030 Page 2 If you should have any questions regarding this matter, please contact Mr. Bradley H.

Blome - Director License Regulatory Assurance at ( 402) 533-6041.

Respectfully,

-fffw/41~

Mary J. Fisher Vice President- Energy Production and Nuclear Decommissioning MJF/cac

Enclosures:

1. Supporting Information for Request for Partial Site Release

2. Computer Disk containing non-NRC referenced documents c: K. M. Kennedy, NRC Regional Administrator, Region IV J. D. Parrott, NRC Senior Project Manager C. D. Steely, NRC Health Physicist, Region IV A. Leek, Bureau Chief, Iowa Department of Health J. Schmitt, Radiological Program Manager, Nebraska Department of Health and Human Services

LIC-18-0030 ,

Page 1 Fort Calhoun Station Supporting Information for Request for Partial Site Release Purpose The purpose of this report is to inform the Nuclear Regulatory Commission (NRC) of Omaha Public Power Districts' (OPPD) intent to remove a portion of the Fort Calhoun Station (FCS) site from the Part 50 license (License No. DPR-40). Specifically, OPPD intends to remove/release two (2) non-impacted survey units from its Part 50 License in accordance with 10 CFR 50.83(b)

"Release of Part of a Power Reactor Facility or Site for Unrestricted Use" and 10 CFR 100, "Release Site Criteria." OPPD has reviewed and assessed the subject property to ensure that the release of subject land area will have no adverse impact on the ability of the site in aggregate to meet 10 CFR 20, Subpart E, criteria for unrestricted release. This report contains a summary of the assessment performed, as well as a summary of the characterization surveys performed in these survey units. It is noted that this report does not contain the Final Status Survey (FSS) report for this area because the survey units within this area are characterized as non-impacted and as such, no statistical tests, scan and static measurement or elevated measurement comparison are required . Figure 1 provides a description of the site's owner controlled area (OCA) and Figures 2, 3, and 4 depict an overview of all the survey unit boundaries and the site boundary/subject non-impacted survey unit sample coordinates, respectively.

LIC-18-0030 Page 2 Figure 1- Fort Calhoun Station Owner Controlled Area

LIC-18-0030 Page 3 Ced oe,~omes

• Ottumwa P2rfal Site Release SIJ'Vey Urits FortCallll<m Blair. NE D Site Boundary 10/23/2018 18062201 .D Figure 2 - Non-Impacted Open Land Survey Units

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LI C-18-0030 Page 6

Background

FCS consists of one Pressurized Water Reactor (PWR). The station is located near the city of Fort Calhoun on the eastern boarder of central Nebraska. The site location is on the banks of the Missouri River approximately 19 miles north of Omaha, Nebraska and 4 miles south of Blair, Nebraska.

The station is comprised of a Combustion Engineering pressurized water reactor with supporting facilities. The primary coolant system consisted of two heat transfer loops. Each loop contained one steam generator and two reactor coolant pumps with associated piping and valves. In addition, the primary coolant system included a pressurizer, pressurizer relief tank, interconnecting piping, and the instrumentation necessary for operational control. All major components of the primary coolant system are located within the containment building.

The construction permit was issued by Atomic Energy Commission (AEC) on June 7, 1968, and operating license was issued August 9, 1973. The plant began commercial operation on September 26, 1973. A license was requested to operate the facility at power levels up to and including 1420 core thermal megawatts (MWt) which corresponded to a turbine-generator output of 481 MWe. The license was then amended to allow operation at power levels up to and including 1500 core thermal megawatts (MWt) which corresponded to a turbine-generator output of nominal 533. 7 MWe at 0.90 power factor.

On June 24, 2016 and updated on August 25, 2016, FCS submitted the Certifications of Permanent Cessation of Power Operations (References 1 and 2) in accordance with 10 CFR Part 50.82(a)(i). On November 13, 2016, FCS submitted the Certification of Permanent Removal of Fuel from the Reactor Vessel (Reference 3) to the NRC in accordance with 10 CFR Part 50.82(a)(1)(ii). On March 30, 2017, FCS submitted the Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 4) and on March 31, 2017 FCS submitted an updated Irradiated Fuel Management Plan (FMP) (Reference 5). Therefore, the 10 CFR Part 50 license for FCS no longer will permit operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR Part 50.82(a)(2). OPPD has previously submitted a partial site release request to the NRC for approximately 120 acres.

(Reference 22)

LIC-18-0030 Page 7 Evaluation of Effect of Proposed Release FCS evaluated the effects of releasing a portion of land north and east of the OCA totaling approximately 475-acres from the Part 50 License in accordance with the criteria specified in 10 CFR 50.83(a)(1-3) in order to ensure that FCS will continue to comply with all applicable statutory and regulatory requirements that may be affected by the release of the subject property.

Specifically, OPPDs' evaluation confirmed the following with respect to each of the regulatory areas identified in 10 CFR 50.83(a)(1 )(i)-(vi), (a)(2), and (a)(3):

(a)(1) Evaluate the effects of releasing the property to ensure that:

i. The dose to individual members of the public does not exceed the limits and standards of 10 CFR Part 20, Subpart D.

The OPPD FCS controls and monitors effluents to ensure radioactivity released to the environment is maintained ALARA and does not exceed federal release limit criteria.

Effluent controls include operation of radiation monitoring systems as well as an offsite environmental analysis program. The release of the northern and eastern 475-acres of the additional exclusion area, as defined by the 1973 and 1978 easements, does not change any controls used to comply with dose limits for individual members of the public and the conservatively estimated yearly dose to a member of the public is well below the 10 CFR Part 20, Subpart D limits and standards.

A review of the Annual Effluent Report shows the Optically Stimulated Luminescence Dosimeter (OSLO) readings for the doses to members of the public are well below the regulatory limits set forth in both Environmental Protection Agency (EPA) and NRC dose limits.

ii. There is no reduction in the effectiveness of emergency planning or physical security.

No credit is taken for the subject land in the Emergency Plan. However, the release was reviewed by Emergency Planning under the 10 CFR 50.54(q) and the Security Plan was reviewed under the 10 CFR 50.54(p) process. The evaluations concluded the release of the subject property has no adverse effect on either plan. Actions are assigned to Emergency Planning Department to evaluate the impact due to the changes in the exclusion area boundary (EAB) upon approval.

iii. Effluent releases remain within license conditions.

FCS programs to monitor and measure effluent releases within license conditions remain in effect and the early release of the subject property does not have an impact on these programs. Effluent monitoring conditions will remain in effect in accordance with license conditions. Environmental dose monitoring locations will not change as a result

LIC-18-0030 Page 8 of this proposed land release. Therefore, the effluent releases from FCS will remain in accordance with license conditions.

iv. The environmental monitoring program and offsite dose calculation manual

{ODCM) are revised to account for the changes.

Changes to the site boundary have the potential to affect concentrations in offsite dose pathways. The FCS ODCM has been evaluated and will be updated to address the reduced land area and any potential land use in conjunction with implementation of partial site release request. Occupancy factors remain unchanged with the subject land release.

The Environmental Impact Statement is not affected by the subject land release. There are no expected changes to the external appearance of the plant; changes to waste processing; changes in land or water usage; changes in water or air quality; changes in radiological impact; or changes to historical or archeological areas. The socioeconomic impact of the release is neutral as the farmer who owns and farms the land will continue to do so after the release approval.

v. The siting criteria for 10 CFR 100 continue to be met.

The release of the subject property has been reviewed with respect to the siting criteria in 10 CFR 100 and it has been determined that the requirements of 10 CFR 100 are either not impacted or are not applicable. The radiological EAB at FCS is being updated to approximately 464 meters per engineering calculations (Reference 17). The dose at that distance from the Auxiliary Building effluent stack is well below the 10 CFR 100 criteria of 25 rem in two hours or 300 rem to the thyroid in that same time period. The member of the public that is analyzed to receive the highest dose is postulated to receive 1 mrem total effective dose equivalent {TEDE) from an accident or event analysis (Reference 17). FCS will continue to maintain the ability to remove members of the public from the exclusion area in the case of radiological emergency.

vi. All other applicable statutory and regulatory requirements continue to be met.

There are no significant changes to the FCS policies and procedures to ensure that statutory and regulatory requirements continued to be met as a result of this early release of the subject property.

In summary, the proposed release of the approximately 475-acres from the Part 50 License will not have any impact on FCS continued compliance with applicable NRC standards.

{a){2) Perform a historical site assessment of the part of the facility or site to be released.

In accordance with guidance provided in NUREG-1575, "Multi Agency Radiation Survey and Site Investigation Manual (MARSSIM)" (Reference 6), section 3.0, a Historical Site Assessment (HSA) (Reference 15) was performed for all areas outside of operational structures and documented in 2016 after FCS was permanently taken offline for decommissioning. Historical

LIC-18-0030 Page 9 information, including any 10 CFR 50.75(g) files, employee interviews, radiological incident reports, pre-operational survey data, spill reports, special surveys, operational survey records, and Annual Radiological Operating Reports (including sampling of air, groundwater, milk, fish, and surface vegetation) were reviewed and compiled for this investigation.

The HSA was a detailed investigation of all non-operational areas of the OCA to collect existing information for the site and its surroundings. The HSA focused on historical events and routine operational processes that could have resulted in contamination of onsite buildings outside of the Protected Area (PA); surface and subsurface soils within the PA; as well as open land areas; subsurface soils outside of the PA, but within the OCA. The information compiled by the HSA was used to establish initial area survey unit classification of the subject land. The scope of the HSA includes potential contamination from radioactive materials, hazardous materials, and environmental contaminants.

The HSA investigation was designed to obtain sufficient information to provide initial classification of site land areas and structures as impacted or non-impacted. Impacted areas have a potential for contamination (based on historical data) or contain known contamination (based on preliminary radiological surveillance). MARSSIM defines non-impacted areas as those areas where there is no reasonable possibility of residual contamination.

As the HSA was focused on the OCA and the subject land is outside of such area, a Phase I Environmental Site Assessment was performed by Haley & Aldrich (reference 8). This review included a review of records, historical disposition, and discussion with the land owner. The purpose of the review was to determine any environmental impacts due to FCS's operation on the subject land. FCS's connection to the land has always been that of an easement. No operational activities were ever performed on the subject land. The Phase I Environmental Review determined there were no adverse environmental impacts to the subject property due to FCS operation.

Based on a review of the operating history of the facility, any historical incidents as documented in the HSA, and the Phase I Environmental Review, as well as subsequent characterization surveys discussed in the next section, the subject open land areas to the north and east of the OCA were deemed not impacted by licensed activities or materials. Therefore, it was determined that the non-impacted classification is appropriate.

(a)(3) Perform surveys adequate to demonstrate compliance with the radiological criteria for unrestricted use specified in 10CFR20.1402 for impacted areas.

MARSSIM Section 2.5.2 states, "Non-impacted areas represent areas where all of the information necessary to demonstrate compliance is available from existing sources. For these areas, no statistical tests are considered necessary." Additionally, Table 2.2. of MARSSIM, "Recommended Conditions for Demonstrating Compliance Based on Survey Unit Classification for a Final Status Survey," requires no elevated measurement comparison, no sampling , and/or direct measurements and no scanning to be performed in non-impacted areas. Despite this available waiver, a comprehensive characterization was performed.

The site release criteria for the subject land at FCS correspond to the 10 CFR 20.1402 criteria for unrestricted use. The residual radioactivity, including that from ground water sources, that is distinguishable from background, must not cause the TEDE to an average member of the

LIC-18-0030 Page 10 critical group to exceed 25 mrem/yr. The residual radioactivity must also be reduced to levels that are ALARA.

The characterization survey was designed and executed using the guidance provided in MARSSIM and NUREG-1757, Volume 2, Revision 1, "Consolidated Decommissioning Guidance-Characterization, Survey, and Determination of Radiological Criteria, Final Report. "

(Reference 7) In addition, surveys were designed and executed in accordance with MARSSIM guidance, NUREGs -1757 and -1575, industry data, and benchmarking input from other decommissioning organizations. Analyses of background radiation and Cs-137 in background (Reference 10), radionuclides of concern (Reference 9), soil DCGLs (Reference 21 ), and Soil Minimum Detectable Concentrations for 2x2 Nal Probes (Reference 11) were completed and utilized in survey design. Both Data Quality Objectives and survey methodology were included in detailed survey plan, (Reference 20). These describe the process, organization, functional sample activities, Data Quality Objective process, and measures necessary to conduct surveys in the field. The surveys were carried out via those detailed survey package documents (Reference 14).

Areas classified as non-impacted received surveys developed to include a systematic and biased survey measurements locations and scan areas. Due to accessibility with currently farmed land, large areas were judgmentally chosen in areas likely to contain the highest concentrations and then randomly chosen points were generated to cover 1% of the total land.

Systematic survey design selected static measurement or sample locations at random. This was chosen utilizing at Class Ill model for survey design.

In August and September 2018, sufficient survey coverage (1%) and an adequate number of samples (14 per unit) were obtained in the subject survey units to serve as the basis for the non-impacted classification. Within each of the survey units specified, the survey focused primarily on surface (0 to 15 cm) soil.

The characterization survey of each unit consisted of quantitative analysis results. Verification gamma scans using a Nal detector were performed with speeds and distances in accordance with FC-18-006 (Reference 11 ). MDCs and gamma scanning sensitivities were estimated based on the assumed geometry and the potential plant-derived gamma-emitting radionuclides that may be present. Quantitative analysis results were obtained from radionuclide specific analysis of surface soil media using a calibrated counting geometry. Analysis times were set to achieve the required MDCs that were based on DCGLs and expected Cs-137 background due to global fallout.

The minimum number of random-based direct measurements and soil samples was chosen utilizing MARSSIM guidance and the Sign test. Surface scanning using a Nal detector was performed in a square area around a randomly chosen center point to approximate at least one percent of the total area of a given survey unit.

The non-impacted subject land area in the Iowa easement is approximately 475 acres. Some areas were considered inaccessible from a sampling standpoint due to farmed land and river condifions. Areas were cleared or chosen for their ability to be scanned. As such, all areas selected were able to be scanned by Nal detector and a soil sample obtained. However, in the

LIC-18-0030 Page 11 random generation of sample points, a few locations (< 10%) were thrown out and a new point randomly generated due to the safety of the personnel access or a portion of the scan area landing within the Missouri River.

For the Nal detector scanned areas, post-sampling data review was conducted on the approximately 21,000 data points which were logged at one second intervals with a Trimble GPS unit. The analysis of the data utilized an action level of minimum detectable count rate (MDCR) plus background . Any points which exceeded that threshold and in which an adjacent point also exceeded the threshold would be re-surveyed. Background data was obtained at several locations determined to be similar in both land-use and geology. Three distinct types were identified (field, treed, and sand). Action levels were applied to each background type.

The scans did not identify any locations that required further survey or examination. All areas surveyed showed count rates consistent with the expected background count rate for that area (Reference 13).

Additional detail on the survey results of the radiological analysis of each measurement and soil sample obtained during the characterization of the subject non-impacted open land survey units are presented in FCS's (Reference 13), "Partial Site Release Data - Iowa Easement." Based on the results of the characterization surveys performed of the subject non-impacted open land area, it can be concluded that a non-impacted classification for these areas is appropriate as all measurements were less than the action level. Cs-137 was the only radionuclide positively identified that could be potentially classified as plant-derived; however, the concentrations observed were well within the range of activity defined as background due to global fallout.

Non-impacted areas are defined in MARSSIM as areas that have no reasonable potential for residual contamination, no radiological impact from site operations and are typically identified during the HSA. FCS has found no evidence of using, storing, or burying radioactive materials in the subject property. Therefore, based on sample measurements and historical use information, it can be concluded that the release of the subject land area will have no adverse impact on the ability of FCS to meet the Part 20, Subpart E requirements for unrestricted release.

Description of the Property For non-impacted areas, 10 CFR 50.83 (b )(2) requires a description of the part of the facility or site to be released . The owner-controlled site is approximately 660 acres; 565 acres of this area is on the alluvial flood plain of the Missouri River. An additional exclusion area of approximately 582-acres is included on the northeast bank of the Missouri River directly opposite the plant building. This additional exclusion area provided means of perpetual easements, which allows OPPD to restrict or prohibit access should evacuation be necessary.

More specifically on October 24, 1973,(reference 18) and on March 30, 1978, (reference 19) the owners of property located across the Missouri River from OPPD's FCS executed easements in perpetuity to OPPD. The property that is subject to this release is the approximately 475-acre parcel of uninhabited, undeveloped land that has not been negatively impacted by FCS operation or subsequent decommissioning activities.

The legal description of the subject land is described as follows below:

LIC-18-0030 Page 12 October 24, 1973 Agreement:

The West One-half (W2), except the North One Thousand feet (1,000') thereof, together with all accretions thereto extending to the Nebraska-Iowa Compact line and the Northeast Quarter (NE3 ), except the North One Thousand feet (1,000') and the East Five Hundred feet (500')

thereof and the Southeast Quarter (SE3 ), together with all accretions thereto extending to the Nebraska-Iowa Compact line, all in Section Twenty-five (25) and that part of the Northeast Quarter (NE3 ), of Section Thirty-six (36), lying Northeast of the Nebraska-Iowa Compact line, all in Township Seventy-eight (78) North, Range Forty-six (46), West of the 5th P.M., Harrison County, Iowa; that part of the Southwest Quarter (SW3) of Section Thirty (30) described as follows: All that land lying Southwest of a line extending from the Northwest corner thereof to the Southeast corner thereof; and the West Twenty-nine Hundred and Seventy feet (2,970') of the North One-half (N2) of Section Thirty-one (31 ), together with all accretions thereto extending to the Nebraska-Iowa Compact line, and all of Government Lots 1, 3, and 7 in Section 31, whether lying North or South of the Nebraska-Iowa Compact line, all in Township Seventy-eight (78) North, Range Forty-five (45), West of the 5th P.M., Harrison County, Iowa.

The legal description of the easement agreement of March 30, 1978 is as follows:

A tract of land in the North One-half of Section 31, Township 78 North, Range 45 West of the 5th P.M., Harrison County, Iowa, being more particularly described as follows: Beginning at the point of intersection of the South line of the North One-half of Section 31-78-45 and the Nebraska-Iowa compact line; thence N 30°05'35" W along the compact line a distance of 239.96 feet; thence N 28°04'05" W, a distance of 863.08 feet to the point of intersection of the Nebraska-Iowa compact line and the design right bank of the Missouri River; thence S 71 °01 '48" E along said right bank a distance of 135.92 feet; thence S 73°37'43" E, a distance of 500.22 feet; thence S 75°11'38" E, a distance of 147.06 feet; thence S 76°21'54" E, a distance of 524.11 feet; thence S 78°41 '38" E, a distance of 338.81 feet; thence S 79°35'38" E, a distance of 70.65 feet to a point of intersection of the design right bank and a line that is 2,970 feet East and parallel to the West line of said Section 31-78-45; thence S 02°40'52" E along said line a distance of 490.00 feet to the South line of the North One-half of said Section 31-78-45; thence S 87°19'1 O" W along said South line a distance of 1,159.50 feet to the point of beginning.

The subject property is located in the western portion of central Iowa in Harrison County, Iowa.

The sites location is on the banks of the Missouri River approximately 19.4 miles north of Omaha, Nebraska and 4 miles south of Blair, Nebraska. The closest residence is 0.6 miles

(=965 meters) from the center of FCS's containment building.

Based upon the information compiled in the HSA and Phase I Environmental Review, the two (2) open land survey units received an initial classification as non-impacted. Non-impacted areas have no reasonable potential for residual contamination because of historical information indicates there was no known impact from site operations. These outlying areas have no impact from site operations based upon the location(s) of licensed operation, site use, topography, site discharge locations and other site physical characteristics. These areas are not required to be surveyed to demonstrate compliance beyond any characterization surveys performed to provide a basis for the classification. The approximately 475-acre parcel has

LI G-18-0030 Page 13 limited access for personnel or vehicle transit due to controlled access and use of the parcel for agricultural purposes.

Schedule for Subject Property Release For the two non-impacted areas, 10 GFR 50.83(b )(3) requires the schedule for the release of the property. Therefore, OPPD requests the NRG approve the acceptability of the release of the subject property from Part 50 License by May 31, 2019.

Results of 10 CFR 50.59 Evaluation 10 GFR 50.83(b )( 4) requires for non-impacted areas that the licensee submit the results of the evaluation performed in accordance with 10 GFR 50.59. The assessment of the release of the subject property are as follows:

The 10 GFR 50.59 review (Screening #18-060) (Reference 12) assessed the impact of the change in the site boundary on offsite dose calculation and effluent releases and conclude that the change:

• Does not adversely affect any design function as described in the Post Shutdown Defueled Analysis Report (PSDAR)(Reference 8)

• Does not adversely affect how a design function as described in the PSDAR is performed or controlled

• Does not revise or replace an evaluation method used to establish design basis of safety analysis, and

• Does not involve a test or experiment not described in the PSDAR.

Environmental Impacts Under 10 GFR 50.83(b)(5), a request for NRG approval of a release of non-impacted areas must include the reasons for concluding that the environmental impacts associated with the proposed release of property will be bounded by appropriate previously issued Environmental Impact Statements in the Generic Environmental Impact Statement for FGS. (Reference 16)

OPPD has evaluated the environmental impacts associated with the proposed release of the subject land and considered those impacts in light of the Final Environmental Impact Statement (FEIS). The evaluation did not identify any significant new environmental impacts or significant changes from the environmental impacts previously assessed by the NRG. In particular, the evaluation found as follows.

• The land transfer will have no more than a negligible increase in offsite dose consequences and no change in effluent releases.

• The OPPD radiological monitoring program will account for the revised site area boundary, and no increases in effects are anticipated.

LI C-18-0030 Page 14 Accordingly, OPPD concludes that the environmental impacts associated with the proposed release of the subject property are bounded by the NRC's previous or current reviews, of the FCS facility.

Additional Areas to be Addressed to Support Release of the Subject Property Statement of Dismantling Activities No dismantlement activities are required in the subject survey units.

Potential for Cross-Contamination from Subsequent Activities The potential for cross-contamination of the subject non-impacted areas due to subsequent decommissioning activities is diminutive. The subject areas are not part of the OCA and not adjacent to any decommissioning activities. In the event that these survey areas are compromised, evaluations will be performed and documented to confirm the no radioactive material was introduced into the area that would affect the results of the FSS. Radioactive material generated during the decommissioning process will be handled and controlled in a manner to prevent contamination of non-impacted areas. These controls include contamination containment measures, dust control measures, storm water runoff control measures, and proper radiological protection implementation.

Impact of Releasing the Subject Property of Part 50 License Basis The license basis for FCS includes the maintenance of certain programs to fulfill regulatory requirements and functional responsibilities. Throughout decommissioning, the programs will be modified as necessary and terminated when the applicable concern is no longer relevant.

These program changes are implemented using the change process specified for each type of program . The methodology for releasing land requires a review and assessment of the impact on license program for the site lands remaining within the domain of the Part 50 License.

• The Technical Specifications are not impacted by the early release of the subject property

• The Defueled Safety Analysis Report (DSAR) will require minor changes to describe the reduced site licensed area boundaries resulting from the release of the subject property from the Part 50 License.

• The Radiological Groundwater Protection Program will not be affected by the early release of the subject property.

• The Fire Protection Program will not be affected by early release of the subject property.

• The Training Program will not be affected by the early release of the subject property.

Conclusion The release of the subject property is part of OPPD's overall efforts to terminate FCS Part 50 License and to achieve unrestricted release of the entire site (with the exception of the ISFSI area) in accordance with the criteria in subpart E of 10 CFR 20.

LI G-18-0030 Page 15 In addition, 10 GFR 50.82(a)(11) establishes the criteria to be used by the NRG for terminating license of a power reactor facility. These criteria include ( 1) dismantlement has been performed in accordance with the approved license termination plan and, (2) the final radiation survey and associated documentation that the facility and site have met the criteria for decommissioning in 10 GFR 20, Subpart E. This early release of the subject property area also supports the process of license termination by demonstrating that this portion of the site lands can be released from FGS license.

This report along with future reports provide documentation that demolition activities have been performed in accordance with the station procedures and the characterization survey confirms the residual radioactivity in each survey unit meets the established criteria. The action of the early release of the subject land supports the overall license termination process in accordance with NRG regulations.

In summary, based on the considerations discussed above, this release of the subject property from the FGS Part 50 License has no impact of OPPD's continued compliance with applicable NRG regulatory standards. OPPD has determined that we have adequately classified the property to be released as non-impacted. Accordingly, OPPD is requesting the NRG to approve the requested release.

LIC-18-0030 Page 16 References

1. Letter from OPPD (T. Burke) to USN RC (Document Control Desk}, "Certification of Permanent Cessation of Power Operations," dated June 24, 2016 (LIC-16-0043)

(ML16176A213)

2. Letter from OPPD (T. Burke) to USN RC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated August 25, 2016 (LIC-16-0067)

(ML16242A127)

3. Letter from OPPD (T. Burke) to USN RC (Document Control Desk), "Certification of Permanent Removal of Fuel from the Reactor" dated November 13, 2016 (LIC-16-0074)

(ML16319A254)

4. Letter from OPPD (M. Fisher) to USN RC (Document Control Desk), "Post-Shutdown Decommissioning Activities Report (PSDAR)," dated March 30, 2017 (LIC 0033)(ML17089A759)

5. Letter from OPPD (M. Fisher) to USN RC (Document Control Desk),"lrradiated Fuel Management Plan," dated March 31, 2017 (LIC-17-0031)(ML17093A594)

6. U.S. Nuclear Regulatory Commission NUREG-1575, Revision 1, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)" -August 2000

7. U.S. Nuclear Regulatory Commission NUREG-1757, Volume 2, Revision 1, "Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria, Final Report" - September 2006

8. "ASTM Phase I Environmental Site Assessment OPPD Easement of Riverside Farm Parcels" by Haley & Aldrich, dated 6 November, 2018

9. FC-18-002, "Potential Radionuclides of Concern During the Decommissioning of Fort Calhoun Station." Blair: Fort Calhoun Station, 2018

10. FC-18-003, "Evaluation of Cs-137 Global Fallout in Soils at Fort Calhoun Station." Blair:

Fort Calhoun Station, 2018

11. FC-18-006, "Soil Minimum Detectable Concentrations for 2x2 Nal Probes." Blair: Fort Calhoun Station, 2018.

12. EC 70009, "Partial Site Release- Phase 2." Blair: Fort Calhoun Station, 2018.

13. FC-18-014, "Partial Site Release Data - Iowa easement." Blair: Fort Calhoun Station, 2018.

14. FCS Partial Site Release Survey Packages and Preparation Instructions. Blair: Fort Calhoun Station, 2018.

15. TSSD. Fort Calhoun Station Limited Radiological and Non-Radiological Site Characterization Survey Reports. Oakland: TSSD Services, 2017.

16. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 12, Regarding Fort Calhoun Nuclear Power Station, August 2007.

17. EC 69954, "Partial Site Release- Phase 1." Blair: Fort Calhoun Station, 2018.

18. Easement October 24, 1973

19. Easement March 30, 1978

20. FC-18-015, "Survey Plan- Iowa Non-impacted Open Land Survey Units." Blair: Fort Calhoun Station, 2018.

21. FC-18-004, "Soil DCGLs for Fort Calhoun Station Outside the Protected Area Identified for Partial Site Release." Blair: Fort Calhoun Station, 2018

22. Letter from OPPD (M. Fisher) to USNRC (Document Control Desk), "Request for Partial Site Release ," dated June 29, 2018 (LIC-18-0023) (ML18215A187)