ML22119A247
| ML22119A247 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/03/2022 |
| From: | Jack Parrott Reactor Decommissioning Branch |
| To: | Via T Omaha Public Power District |
| Jack Parrott, 301-415-6634 | |
| References | |
| EPID L-2021-LIT-0000 | |
| Download: ML22119A247 (5) | |
Text
Troy Via, Chief Operation Officer and Vice President Utility Operations Omaha Public Power District Fort Calhoun Station Mail Stop FC-2-4 9610 Power Lane Blair, NE 68008
SUBJECT:
FORT CALHOUN STATION, UNIT NO. 1 - REVIEW OF LICENSE AMENDMENT REQUEST TO ADD LICENSE CONDITION TO INCLUDE LICENSE TERMINATION PLAN REQUIREMENTS - REQUEST FOR ADDITIONAL INFORMATION (EPID L-2021-LIT-0000)
Dear Troy Via:
By letter dated August 3, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21271A178), as supplemented by letter dated January 13, 2022 (ADAMS Accession No. ML22034A602), Omaha Public Power District (OPPD) submitted a license amendment request for Fort Calhoun Station, Unit No. 1 (FCS). The proposed amendment would add License Condition 3.D to include License Termination Plan (LTP) requirements.
To support the U.S. Nuclear Regulatory Commission (NRC) staffs environmental review of the LTP amendment pursuant to the regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 51, that implement the National Environmental Policy Act of 1969, as amended, please provide the additional information described below. The NRC developed these requests for additional information (RAI) using the guidance in NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs in its review of the application.
This informational need was conveyed to your staff during the periodic licensing call on April 28, 2022. In that call, the NRC staff identified that the following information was needed to begin its technical review:
Historic and Cultural Resources 1.
The historic town of DeSoto has been deemed eligible as a historic property. In the Post-Shutdown Activities Report (PSDAR) closeout letter dated November 3, 2020; staff also requested that the record be updated to identify DeSoto as an eligible historic property. Please provide information regarding the location of the Town of DeSoto and mitigation measures to assure that the property will not be affected by license termination plan activities.
May 3, 2022
T. Via 2.
The NRC staff requested that OPPD consult with the Nebraska State Historic Preservation Officer (SHPO) to determine if the FCS itself could be considered an eligible historic property. Please provide confirmation of the determination from the Nebraska SHPO regarding the eligibly of the FCS itself.
3.
The NRC staff requested in an RAI on the PSDAR that revised PSDARs designation of the eligibility for listing of the townsite of DeSoto on the National Register of Historic Places be corrected based on records that identify that the DeSoto townsite was formally determined eligible for listing on the National Register of Historic Places in 1989. This information should be corrected in the LTP application.
4.
The Environmental Report (ER) for the LTP states that Environmental review procedures have been put in place at FCS regarding undertakings that involve land disturbing activities in undisturbed surface and subsurface areas. Are there any planned decommissioning activities on previously undisturbed land?
5.
What are the results of the 2013 and 2014 reviews of historic, cultural, and archaeological resources mentioned on page 8-23 of the LTP? What did these reviews involve? Were the reviews coordinated or shared with the SHPO?
Waste Management 6.
Application page 8-12 of the LTP states that The total volume of LLRW [low-level radioactive waste] for disposal was estimated in the Decommissioning Plan to be approximately 6,000,000 cubic feet. The LTP application, page 3-21, states the total volume of radioactive waste for disposal has been estimate at 3,222,861 cubic feet.
Please explain the difference between these two estimates.
Cumulative Impacts 7.
Provide a discussion on past, present, and reasonably foreseeable future actions that may result in a potential for cumulative environmental impacts within an 80km [50mi]
radius of the FCS site or within the boundaries of each resource area. This additional information is needed in accordance with 10 CFR 51.45(c), which requires that the ER contain an analysis of cumulative impacts that may result from the proposed action.
Socioeconomics 8.
The Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (NUREG-0586, Supplement 1) states that the two primary pathways through which nuclear power plants activities create socioeconomic impacts on the area surrounding the plant include: 1) through expenditures in the community by the facility workforce and direct purchases of goods and services necessary for facility operation; and 2) the effects on local government tax revenues and services. Section 8.6.3.5.1 of the LTP application states that the work force at FCS has decreased significantly from the time the plant ceased operation in 2016 to a work force of approximately 300 people and will temporarily increase during decommissioning by approximately 150 people.
However, the LTP does not provide the workforce at the time the plant ceased operation or any potential decreases in workforce as decommissioning progresses.
T. Via To support the staffs evaluation of socioeconomic impacts of decommissioning, the NRC requests the following information:
a.) Provide the workforce at the time the plant ceased operation?
b.) Has there been any changes to the estimated 300 current workforce or the additional 150 anticipated during decommissioning? If so, provide this information.
c.) After the temporary increase in workforce, does OPPD anticipate the workforce will remain at 300 workers as decommissioning progresses, or will the workforce decrease below 300 workers? If the workforce will decrease below 300, provide the anticipated number of workers.
9.
The NUREG-0586 Supplement 1 states that the two primary pathways through which nuclear power plants activities create socioeconomic impacts on the area surrounding the plant include: 1) through expenditures in the community by the facility workforce and direct purchases of goods and services necessary for facility operation; and 2) the effects on local government tax revenues and services. The Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Fort Calhoun Station Unit 1 - Final Report (NUREG-1437, Supplement 12 identifies that OPPD is exempt from paying State-occupational, personal-property, and real-estate taxes and instead OPPD makes payments in lieu of taxes to municipalities and counties. The LTP does not provide tax payment information, payments in lieu of taxes, or other forms of payments to local jurisdictions and any anticipated changes during the decommissioning phase.
To support the staffs evaluation of socioeconomic impacts of decommissioning, the NRC requests the following information:
a.) Provide payments in lieu of taxes to local jurisdictions for the past 5 years OPPD made on behalf of FCS and identify the distribution to each local jurisdiction.
b.) Provide anticipated changes to payments in lieu of taxes and other types of payments to local jurisdictions during the decommissioning phase of FCS.
- 10. Section 8.6.3.12 of the LTP states that low-income and minority populations are present in the vicinity of the former FCS. The LTP further states that a refurbished rail spur will be used to transport waste and that decommissioning activities will cause an increase in truck traffic and that there will be no environmental justice impact relative to rail and truck transportation because of decommissioning. The LTP, however, does not provided a discussion or basis for why there will be no environmental justice impacts to minority and low-income populations along route rail and truck transportation routes.
Discuss and provide the basis for concluding there would be no disproportionately high and adverse human health and environmental effects (e.g., noise, traffic) on minority and low-income populations that live along rail and truck transportation routes.
T. Via We request that the supplemental information requested above be provided within 30 days from the date of this letter. If you have any questions, please contact me at (301) 415-6634 or Jack.Parrott@nrc.gov.
Sincerely, Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-285 cc: Fort Calhoun Listserv Becki Harisis, Manager Office of Radiological Health Nebraska Department of Health & Human Services 301 Centennial Mall South P.O. Box 95026 Lincoln, NE 68509-5026 Becki.Harisis@nebraska.gov Angela Leek, Bureau Chief Bureau of Radiological Health Iowa Department of Public Health angela.leek@idph.iowa.gov Signed by Parrott, Jack on 05/03/22
Ltr ML22119A247 OFFICE NMSS/DUWP/RDB NMSS/REFS/ERMB NMSS/DUWP/RDB NMSS/DUWP/RDB NAME JParrott JCaverly BWatson JParrott DATE May 2, 2022 May 3, 2022 May 3, 2022 May 3, 2022