ML22264A327

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Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII
ML22264A327
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Site: Vallecitos Nuclear Center, Vallecitos
Issue date: 09/21/2022
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GE Hitachi Nuclear Energy
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Office of Nuclear Material Safety and Safeguards
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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report GE - Hitachi Nuclear Energy Alameda County, California Rev. XII September 21, 2022

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Table of Contents Page

1.0 INTRODUCTION

...............................................................................................................1 1.1 Purpose ..............................................................................................................................1 1.2 Summary ...........................................................................................................................1 2.0 Background and History ......................................................................................................3 3.0 VBWR Licensing Bases and Conditions .............................................................................7 3.1 LPSDAR Licensing Considerations ..................................................................................7 3.2 VBWR Licensing Conditions............................................................................................8 3.3 EVESR License Conditions ............................................................................................13 3.4 EVESR (NRC Possession-only DR-10 License, Amendment 7, 12/1/2008 [Technical Specifications]) ..........................................................................................................................14 4.0 PLANNED DECOMMISSIONING ACTIVITIES ...........................................................16 4.1 Decommissioning Approach ...........................................................................................16 4.1 Decommissioning Phases ................................................................................................16 4.2 Schedule ..........................................................................................................................20 5.0 PROJECT MANAGEMENT .............................................................................................23 5.1 Organization ....................................................................................................................23 6.0 Financial Assurance ...........................................................................................................24 6.1 Decommissioning Cost Estimate ....................................................................................24 7.0 ENVIRONMENTAL REVIEW ........................................................................................25 7.1 Radiological ....................................................................................................................25 7.2 Non-Radiological ............................................................................................................25 8.0 References ..........................................................................................................................32 Appendices:

Appendix A - Decommissioning Cost Estimates i

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII List of Tables Table 4-1, VBWR Schedule 19 Table 4-2, EVESR Schedule ......................................................................................................... 22 Table A-1 VBWR DCE Breakdown ............................................................................................. 33 Table A-2 EVESR & 300 Area DCE Breakdown ........................................................................ 34 List of Figures Figure 2 VNC Site Area ........................................................................................................... 4 Figure 2 VNC 300 Area............................................................................................................ 5 ii

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII List of Acronyms Acronym Meaning ALARA As Low As Reasonably Achievable BMP Best Management Practices Caltrans California Department of Transportation CEO Chief Executive Officer CFR Code of Federal Regulations CNDDB California Natural Diversity Database CRLF California Red-Legged Frog DAW Dry Active Waste (NOT USED IN REPORT (NUIR))

DCE Decommissioning Cost Estimate DCGL Derived Concentration Guideline Levels DCH Designated Critical Habitat EPA Environmental Protection Agency ESADA Empire State Atomic Development Agency EVESR ESADA Vallecitos Experimental Superheat Reactor FSAR Final Safety Analysis Report FSS Final Status Survey GE General Electric GEH GE-Hitachi Nuclear Energy GEIS Final Generic Environmental Impact Statement GETR GE Test Reactor HEPA High-Efficiency Particulate Absorbing Filter (NUIR)

HRA High Radiation Area HSA Historical Site Assessment (NUIR)

IPaC Information for Planning and Consultation LLW Low-Level Radioactive Waste (NUIR)

LTP License Termination Plan MARSSIM NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual mrem Millirem NIST National Institute of Standards and Technology (NUIR) iii

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII NRC U.S. Nuclear Regulatory Commission NRHP National Registry of Historic Places NTR Nuclear Test Reactor NUREG Nuclear Regulatory Commission Regulation OSHA Occupational Safety and Health Administration POL Possession-only Licenses RCRA Resource Conservation and Recovery Act RFP Request for Proposal SNM Special Nuclear Material SSC Systems, Structures and Components T&E Threatened and Endangered TEDE Total Effective Dose Equivalent USCB US Census Bureau USFWS US Fish and Wildlife Service VBWR Vallecitos Boiling Water Reactor VNC Vallecitos Nuclear Center WAC Waste Acceptance Criteria (NUIR) iv

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII

1.0 INTRODUCTION

1.1 Purpose This report constitutes the Limited Post-Shutdown Decommissioning Activities Report (LPSDAR) for the Vallecitos Nuclear Center (VNC) Vallecitos Boiling Water Reactor (VBWR) and Empire State Atomic Development Agency (ESADA) Vallecitos Experimental Superheat Reactor (EVESR). The LPSDAR contains the following:

1. A description of the planned decommissioning activities;
2. An anticipated scheduled for the decommissioning activities; and,
3. A Decommissioning Cost Estimate (DCE) describing the projected cost of decommissioning the VBWR and EVESR.
4. A review of potential environmental impacts associated with the decommissioning activities, showing that all activities can be reasonable controlled and bounded well within the Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (NUREG-0586).(1)

This LPSDAR has been developed consistent with Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report," (1) and bounded by U.S. Nuclear Regulatory Commission (NRC)s letter to Matt Feyrer of VNC dated April 8, 2022, titled GE Hitachi Nuclear Energy, Vallecitos Nuclear Center -Response to the Description for Decommissioning the Shutdown Reactors. (2) It is based on currently available information; plans as described may be modified as needed and as additional information becomes available, or conditions change.

1.2 Summary GE-Hitachi Nuclear Energy (GEH) operates a nuclear facility located in Sunol, California. For this document, the facility, Vallecitos Nuclear Center, is identified as VNC.

It is the intent of GEH to decommission the VBWR and EVESR and terminate their NRC licenses DPR-1 and DR-10, respectively. This decommissioning and license termination will be conducted in accordance with the applicable requirements of 10 CFR 50.82 as identified in (2), removing and disposing of materials and decontaminating both facilities meeting conditions for unrestricted release in accordance with the criteria for decommissioning in 10 CFR 20.1401 and 20.1402.

GEH will follow the general recommendations given by the NRC for the termination of the shutdown reactor licenses at the VNC (3) (4). These are:

1. The VBWR and EVESR reactor vessel will be removed; the Systems, Structures, and Components (SSC) within the containment building will be further decontaminated.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Decommissioning activities will be performed in accordance with the requirements of 10 CFR 50.59.

2. A License Termination Plan (LTP) for VBWR will be submitted by September 8, 2023, pursuant to 10 CFR 50.82(a)(9).
3. The VBWR license will be terminated by September 9, 2025. As needed, GEH will submit a license amendment request to transfer any VBWR residual radioactivity to the EVESR license.
4. Pending the NRCs approval and issuance of an amendment to the EVESR license incorporating the VBWR residual radioactivity and facilities, GEH will request, pursuant to 10 CFR 50.12, an exemption to 10 CFR 50.82(a)(11)(ii) for VBWR that will facilitate the final termination of the VBWR license and decommissioning of the VBWR and EVESR sites together.
5. The LTP for EVESR will be submitted by April 15, 2028, pursuant to 10 CFR 50.82(a)(9).
6. The EVESR license will be terminated by April 15, 2030.

GEH VNC decommissioning activities have begun with an environmental assessment, to identify potential impacts specifically related to threatened or endangered species, and with radiological scoping and characterization surveys to identify radiologically conditions to support planning for decommissioning activities and for radiological classification of areas based on the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), NUREG-1575, Rev 1, August 2000. (5) 2

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII 2.0 Background and History The VNC site is located at 6705 Vallecitos Road (north side of State Route 84) in Sunol, Alameda County, California. The site is east of San Francisco Bay, approximately 35 air miles east-southeast of San Francisco and 20 air miles north of San Jose. The properties surrounding the site are primarily used for agriculture and cattle raising, with some residences, which are mostly to the west of the property. The nearest cities are Pleasanton, with a population of approximately 80,000, located 4.1 miles to the north-northwest and Livermore with a population of approximately 90,000, located 6.2 miles to the northeast.

The original VNC site is understood as an approximate 1600-acre site which includes both the General Electric (GE) property (approximately 610 acres) and the VNC property (approximately 997 acres). The fenced area, commonly referred to as the Site Developed Area, encompasses the buildings and structures associated with the four reactors and is approximately 105.8 acres. (See Figure 2-1, VNC Site Area.) In 1991, GE submitted a request to the NRC to release 2 acres of the original VNC site for unrestricted use by the California Department of Transportation (Caltrans) to modify Highway 84. This request was later approved in 1992. In 2015, GEH submitted a License Amendment Request to the Nuclear Test Reactor (NTR) R-33 license to change the definition of site boundary to exclude the 610-acre GEH property. This request was approved on June 29, 2022, as License Amendment 25. The environmental requirements of this release were performed according to 50.83(b)(5) and (d)(3) and confirmed by the NRCs 20160504 North Section Assessment of No Significant Impact (Agencywide Documents Access and Management System [ADAMS] Accession No. ML16069A155). A request was submitted in 2018 pursuant to 10 CFR 50.83(b) to release about 7 acres along south edge of the property to allow Caltrans to widen Highway 84. This release was approved by the NRC on September 30, 2019 (ADAMS Accession No. ML19249C554).

The VBWR and EVESR licensed area, also known as the 300 area, is approximately 3.2 acres within the 105.8-acre Site Developed Area. Maps of the areas are included as Figures 2-1 and 2-2.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Figure 2 VNC Site Area 4

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Figure 2 VNC 300 Area 5

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII The VNC site was purchased by GE in March 1956, and construction began in June 1956 on the Vallecitos Atomic Laboratory, for nuclear power research, development, testing, and post-irradiation examination of reactor fuels. From approximately 1956 to 1963, Pacific Gas and Electric Company installed and operated a turbine generator at VNC. From 1965 through 1975, and 1981 through 1982, portions of VNC were used by the U.S. Department of Energy (DOE) to conduct research work. GE also conducted research operations as a DOE subcontractor and later transitioned these operations to a private corporation in 1998. (6) As of 2019, GEH employed an on-site staff of approximately 50 people. (6)

The VBWR (DPR-1 Docket 50-18) and EVESR (DR-10 Docket 50-183) are licensed as power reactors under part 50, Domestic Licensing of Production and Utilization Facilities, of Title 10 of the Code of Federal Regulations (10 CFR) Part 50. Both units have permanently ceased operation and are in SAFSTOR with all nuclear fuel removed from the respective reactor vessels of both units. These units are awaiting the termination of the power reactor licenses. The GETR is a shutdown testing facility (also called a test reactor), NRC License TR-1, Docket 50-70. The NTR, NRC License R-33, Docket 50-73 is an operating research reactor.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII 3.0 VBWR Licensing Bases and Conditions 3.1 LPSDAR Licensing Considerations The NRCs 1996 decommissioning rulemaking included changes to 10 CFR 50.82 (61 FR 39278) that codified the application of the PSDAR as the document to be used for supplementing the FSAR for decommissioning activities under 10 CFR 50.59. The PSDAR is to contain an identification and schedule of planned decommissioning activities. A written notification shall be submitted to the NRC before performing any decommissioning activity that is inconsistent with or makes significant schedule changes from the PSDAR.

The 1996 final rule makes these points: 1) the Final Safety Analysis Report (FSAR) is the licensing basis document for performing activities under 10 CFR 50.59, 2) a PSDAR is to be submitted that will contain a schedule of planned decommissioning activities, and 3) the licensee will provide written notification to the NRC before performing any decommissioning activity that is inconsistent with or makes significant schedule changes from the PSDAR.

However, neither the VBWR nor EVESR have, or are required to have, an FSAR or a PSDAR.

Instead, both units continue to be maintained under their original Possession-Only Licenses (POLs). Neither of these licenses serve as functional license basis documents for performing activities under § 50.59 nor do they provide schedules of planned decommissioning activities.

Additionally, several of the conditions of these licenses are obsolete, ambiguous, or irrelevant considering current state.

GEH, through discussions with the NRC, has concluded that the following process provides a suitable licensing and documentation process for the continued decommissioning of the shutdown reactors at the VNC:

This LPSDAR, as an elective submittal by GEH, will provide a PSDAR-like schedule of planned decommissioning activities.

Amendment 16 of the GETR license TR-1 (Sep. 30, 1992) calls for an integrated approach to decommissioning 10 CFR Part 50 reactor facilities and terminate 10 CFR Part 50 reactor licenses for the entire VNC site . In keeping with this condition, it is GEHs intent to extend the application of § 50.59 to provide a consistent change mechanism for the integrated decommissioning effort of the EVESR and GETR facilities.

GEH will notify the NRC before performing any decommissioning activity that is inconsistent with the licensing information provided in or makes significant schedule changes to this LPSDAR.

Each of the VBWR and EVESR License Termination Plans (LTPs), once submitted, will serve as the licensing basis document for performing activities under § 50.59 in lieu of an FSAR.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII A list of conditions in the VBWR and EVESR POLs is provided below where clarification and defined applicability during the decommissioning process is addressed. For each condition, as appropriate, GEH provides a clarifying interpretation, a statement explaining how compliance is met, or suitable means for meeting the intent of the condition.

3.2 VBWR Licensing Conditions 3.2.1 VBWR (NRC Possession-only DPR-1 License, Amendment 21, 10/22/2007)

License Condition 3a: May possess but not separate byproduct material contained in structural parts.

Position: GEH understands this condition to mean that it precludes the use of unlicensed waste reduction or separation processes but does not preclude reasonable methods to decontaminate structural parts or reduce waste volume.

License Condition 4: Maintain audible control device on doors to the containment in lieu of a visible or audible control device at High Radiation Areas (HRA).

Position: GEH understands this License Condition as providing an exemption from the requirements of 10 CFR 20, Subpart G, requiring localized HRA Controls. Therefore, the audible control device may be idled if HRAs in the VBWR containment enclosure are locally posted and controlled. Currently, there are no HRAs in the VBWR; therefore, no alarm, or exemptions, are required. Permanent removal of the alarm on the VBWR containment enclosure will be addressed pursuant to § 50.59.

License Condition 5b: Shall not dispose of the facility or property occupied by the facility without NRC approval except as per 10 CFR 20.

Position: GEH understands this condition to apply to real property and unrelated to materials that can be released or disposed on under the provisions of 10 CFR 20.

License Condition 5d(1): Report any possible unsafe condition by telephone and submit a report within 10 days.

Position: Unsafe condition for a reactor in decommissioning is not defined in the license basis or any other NRC document. The 1996 decommissioning final rule clarifies that changes can be made under 10 CFR 50.59 without prior NRC approval, thereby implicitly indicating that the meaning is not the same as substantial safety hazard. GEH will apply the following for defining an unsafe condition.

Unsafe condition: Any combination of failures in equipment or administrative radiological work controls that result in a worker being assigned an unplanned dose 8

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII equal to or greater than 100 mrem Total Effective Dose Rate (TEDE) or a spill of more than 1,000 gallons of contaminated liquid waste on uncovered (bare) soil.

This following discussion is offered as justification for this definition.

Radiological Safety:

GEH believes that establishing a real exposure threshold eliminates inconsistent and erratic reporting, and so establishes an unsafe condition evident threshold for such reporting at 100 mrem unplanned TEDE to a single individual. 100 mrem is the level given in 10 CFR 19.12 at which workers are to be informed of the potential for them to get 100 mrem/yr. and is substantially lower than the 10 CFR 20 reporting limit of 5 Rem within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

GEH contends that an unsafe condition related to airborne contamination is concurrent with the reporting criterion of 10 CFR 20.2202 and considers unsafe condition in this application duplicitous.

Accordingly, for reporting purposes, an unsafe condition may exist related to radiological safety if any combination of failures in equipment or administrative radiological work controls result in a worker being assigned an unplanned dose equal to or greater than 100 mrem TEDE.

Environmental Safety:

NRCs Regulatory Basis Document entitled; Regulatory Improvements for Power Reactors Transitioning to Decommissioning (ADAMS Accession No. ML17215A010) emphasizes the safety weighting of volumes of liquid radioactive waste maintained on a facility in decommissioning. This document concludes that for level 4 facilities, that is, those with all spent fuel removed from site, storage of liquid radioactive waste becomes the preeminent concern. It further discusses the conclusions of SECY-96-256 that the postulated rupture of a tank of radwaste less the 1,000 gallons presents a significantly reduced impact to onsite cleanup costs than a tank containing more than 1,000 gallons.

In consideration of 10 CFR 50.82(6), GEH concludes that the rupture of a tank less than 1,000 gallons will not foreclose release of the site for unrestricted use, result in significant environmental impacts not previously reviewed, or result in there no longer being reasonable assurance that adequate funds will be available for decommissioning.

As a result, an unsafe condition may exist related to environmental safety if 1,000 gallons of contaminated liquid waste is spilled on uncovered (bare) ground.

Industrial Safety:

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Reporting of injuries or unsafe conditions related to industrial safety are made to Occupational Safety and Health Administration (OSHA) and to the state of California.

The NRC will be notified of any event requiring the transport of a radioactively contaminated person to an offsite medical facility for treatment. The NRC will be notified of any event or situation, related to the health and safety of the public or onsite personnel, or protection of the environment, for which a news release is planned or notification to other government agencies has been or will be made. Such an event may include an onsite fatality or inadvertent release of radioactively contaminated materials.

To preclude redundant reporting, an unsafe condition then is not reckoned relative to industrial safety pursuant to this license condition.

License Condition 5f: Manager, VNC; VP Reactor Facility Safety and Security of GEH; and, Manager GEH Nuclear Energy, shall be US citizens.

Position: According to letters GE, C. Monetta to NRC J. R. Strosnider, dated 1/19/2007, NRC, J. R. Strosnider to GE, C. Monetta dated 2/23/2007, and NRC Safety Evaluation, issued 5/9/2007, this license condition ensures compliance with 10 CFR 50.38 by ensuring no non-US citizen has direct authority over the license holder (i.e.; Manager, VNC and GEH Chief Executive Officer (CEO)) in matters relating to the safety and security of the Vallecitos reactors. Because at that time, the GEH CEO was not a US citizen, a position of VP Reactor Facility Safety & Security who was a US citizen was created. The position of Manager VNC was subsequently filled by a US citizen, who reports to a US citizen holding an executive management position.

All three VNC key management positions have been continuously filled since 2007. The current holders of these positions are:

Manager, VNC - C. Martinez VP Reactor Facility Safety & Security - B. Lockwood Manager GEH Nuclear Energy - J. Wileman .

GEH procedure CP-01-102; Organization Changes, 4.1, ensures changes to organizations involve facility licensing comply with 10 CFR 50.83.

3.2.2 VBWR 1965 Deactivation Report II.A.1: A micro switch is installed on both outer air lock doors that alarm in the control room.

Position: GEH will discontinue the use of the remote door alarm whenever it becomes impractical. See License Condition 4 above.

II.A.2: Absolute filter installed on 1 1/2 penetration to allow CNTMT to breathe.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Position: GEH Change Authorizations CA-07-30 and CA-07-31 provide details for the installation of a rollup door during dismantlement activities in 2007 and bounding information for airborne releases based on conservative estimates of residual radioactivity in the VBWR containment. Installation of the rollup door rendered the containment less than airtight and supported the removal of the breathing filter identified in the 1965 Final Deactivation Report, II.A.2 (and section V); which was no longer performing the function for which it was installed. CA-07-30 and CA-07-31 provided adequate assurance that the removal of the containment breathing filter is an activity that can be performed according to 10 CFR 50.59 because it did (and does) not present a potential to foreclose the release of the site for unrestricted use, challenge reasonable assurance of adequate decommissioning funds, or result in significant environmental impacts not previously reviewed.

II.A.3: Manometer outside CNTMT & periodic readings. Vessel vented via MSA Airline filter on top of control rod nozzles.

Position: GEH will drain the VBWR reactor vessel pursuant to 10 CFR 50.59 and will remove the manometer level indicator when it no longer serves a purpose. Draining of the reactor and removal of the manometer do not present a potential to foreclose the release of the site for unrestricted use, challenge reasonable assurance of adequate decommissioning funds, nor result in significant environmental impacts not previously reviewed.

III.A: Airlocks chained and locked with key controlled by EVESR shift supervisor, and outer door alarms.

Position: There is no designated EVESR shift supervisor position at the VNC. Access control to the EVESR is according to site procedure FMP 6.1. GEH will continue to control access to the VBWR according to site procedures. This may include the removal of chains and locks, which is an activity that can be performed according to 10 CFR 50.59 because it does not present a potential to foreclose the release of the site for unrestricted use, challenge reasonable assurance of adequate decommissioning funds, or result in significant environmental impacts not previously reviewed. The use of door alarms is as described in License Condition 4.

III.A.3: Rx vessel drained to a point below the lowest penetration and refueling ports bolted in place.

Position: See II.A.3.

III.A.4: (Due to HRA) Concrete floor plug covers West ladder well & metal cover locked in place over east ladder to prevent unauthorized entry to basement.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Position: The 1965 Deactivation Report, III.A.4 is clear that the installation of a barrier to preclude entry to the basement was done to control access to a high radiation area.

Due to decommissioning dismantlement activities as well as natural decay of residual radioactivity, no HRAs currently exist in the VBWR. Therefore, the removal of this barrier is justified as a dismantlement activity under 10 CFR 50.59 as it did (and does) not present a potential to foreclose the release of the site for unrestricted use, challenge reasonable assurance of adequate decommissioning funds, nor result in significant environmental impacts not previously reviewed.

III.B.1: Turbine Bldg. valve pit has metal cover and radiation signage.

Position: The Enclosure / Turbine Building Valve Pit and the stack were removed during dismantlement. The removal of these plant components is justified as a dismantlement activity under 10 CFR 50.59 as it did (and does) not present a potential to foreclose the release of the site for unrestricted use, challenge reasonable assurance of adequate decommissioning funds, nor result in significant environmental impacts not previously reviewed.

III.B.2: A metal cap has been secured over the top of the stack to contain contamination remaining in the stack.

Position: See III.B.1.

III.D: SNM and byproduct material controlled under licenses DPR-1 & SNM-130 Position: This statement is obsolete. SNM and byproduct material are controlled under licenses DPR-1 and SNM-960. SNM-960 was issued on September 14, 1966, and superseded all specific SNM licenses that had been used on site on a case-by-case basis.

During the decommissioning process, GEH intends to submit a license amendment request to transfer residual contamination to the EVESR DR-10 license. This amendment will seek termination of the VBWR license at which time the SNM-130 reference will be irrelevant.

V: All enclosure penetrations will be checked to assure complete enclosure isolation.

Position: GEH understands this condition to imply that all access points to the facility are adequately secured to control access and prevent unauthorized entry as the containment is not airtight (see II.A.3).

V: The integrity of the Reactor Vessel and process systems will be verified.

Position: GEH understands this condition is to ensure water does not leak from the vessel. Verifications are performed according to site procedure FMP 6.2 and will be discontinued pursuant to 10 CFR 50.59 when all water is removed from the vessel.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII V: The ventilation air filter will be inspected and changed if necessary.

Position: See II.A.2.

V: Security of all locks, doors, and covers restricted access to the retired areas will be checked.

Position: See III.A 3.3 EVESR License Conditions 3.3.1 EVESR (NRC Possession License, Amendment 6, 10/22/2007)

License Condition 3c: Shall not dispose of the facility or property occupied by the facility without NRC approval except as per 10 CFR 20.

Position: GEH understands this condition to apply to real property and unrelated to materials that can be released or disposed of under the provisions of 10 CFR 20.

License Condition EI: Report any possible unsafe condition by telephone and submit a report within 10 days.

Position: GEH considers an unsafe condition to be any combination of failures in equipment or administrative radiological work controls that result in a worker being assigned an unplanned dose equal to or greater than 100 mrem TEDE or a spill of more than 1,000 gallons of contaminated liquid waste on uncovered soil.

License Condition F: Decontamination activities and decommissioning the facility are as stated in GE application dated 1/19/2007, supplemented on 1/25/2007, 2/23/2007, 3/2/2007, 3/26/2007, 5/16/2007, 5/18/2007, 6/4/2007, 7/6/2007, and 8/9/2007.

Position: The referenced license amendment documents deal primarily with the license transfer from GE to GE-Hitachi. Decontamination and decommissioning of the facility will be according to regulation and will be detailed in the LTP.

License Condition G: Manager, VNC; VP Reactor Facility Safety and Security of GEH; and, Manager GEH Nuclear Energy, shall be US citizens.

Position: This is a conforming amendment that is addressed in the GEH position explained License Condition 5f of the VBWR DR-1 license.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII 3.4 EVESR (NRC Possession-only DR-10 License, Amendment 7, 12/1/2008

[Technical Specifications])

TS A1: The Plant Area shall consist of a controlled access area defined by the Rx CNTMT Building and its ventilation system.

Position: The ventilation system was dismantled and removed per License Amendment 16, Oct 16, 1969. This will be addressed in the LTP.

TS A2: Principle activities are limited to possession of facility, dismantlement other than the vessel, and those authorized by regulatory authority.

Position: This TS will be modified by license amendment request to allow removal of the reactor pressure vessel pursuant to § 50.59.

TS B1: The designated facility supervisor shall have extensive reactor knowledge as necessary to provide an effective safety program.

Position: GEH provides the following clarification. This TS requires that the facility manager shall have extensive reactor knowledge and shall utilize the resources of other General Electric personnel as necessary to provide an effective safety program. GEH takes the position that extensive reactor knowledge is neither well defined, nor is it justifiable for the filling of the position of facility manager given the current state of the EVESR; further, that this condition is a remnant of the original 1968 POL that was issued at a time when reactivation of the reactor was a possibility. At that time, no dismantlement had occurred, fuel was still on site, and the plant was in a condition that made restart possible. Additionally, some systems (e.g., radwaste liquid handling) were being maintained in service until the conclusion of the facility deactivation program.

At present, the facility has been defueled and fuel has been removed from site. Partial dismantlement has occurred beyond any reasonable expectation that the facility will ever function again as a reactor. The current state of the facility requires very minimal reactor knowledge as necessary to provide an effective safety program.

TS C2: A ventilation particulate monitor shall be operable whenever the containment is ventilated.

Position: As per TS A1, the ventilation system has been removed from EVESR.

Therefore, GEH contends that this license condition is satisfied by applying a graded approach to local monitoring of airborne contamination according to the sites radiation protection program.

TS C3: Access to EVESR containment shall be controlled IAW 10 CFR 20.1601.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Position: There are currently no HRAs in the EVESR. GEH will continue to comply with 10 CFR 20, Subpart G and all applicable regulatory guidance relating to controlling access to HRAs.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII 4.0 PLANNED DECOMMISSIONING ACTIVITIES 4.1 Decommissioning Approach The NRC has evaluated the environmental impacts of the following three general methods for decommissioning power reactor facilities in NUREG-0586, Final Generic Environmental Impact Statement (GEIS) on Decommissioning Nuclear Facilities, Supplement 1. (7)

1. DECON: The equipment, structures, and portions of the facility and site that contain radioactive contaminants are properly removed or decontaminated to a level that permits termination of the license after cessation of operations.
2. SAFSTOR: The facility is placed in a safe stable condition and maintained in that state (safe storage) until it is subsequently decontaminated and dismantled to levels that permit license termination. During SAFSTOR, a facility is left intact or may be partially dismantled, but the fuel has been removed from the reactor vessel and radioactive liquids have been drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, thus reducing the levels of radioactivity in and on the material and potentially the quantity of radioactive material that must be disposed of during the decontamination and dismantlement.
3. ENTOMB: Radioactive structures, systems, and components are encased in a structurally long-lived substance such as concrete. The entombed structure is appropriately maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits termination of the license.

After a number of years in SAFSTOR, which included removal of some components and materials from the shutdown reactors, GEH VNC has chosen to begin the DECON method to decommission the VBWR and EVESR. GEH VNC is currently in the planning period during which the site is preparing for safe and orderly transition to dismantlement. When the required regulatory submittal, planning, and preparation are sufficiently complete, the site will move into active decontamination and dismantlement.

4.1 Decommissioning Phases License termination for VBWR will be completed by 9/8/25 and decommissioning activities will be completed for both VBWR and EVESR by 4/15/30. Three phases of the decommissioning activities are:

1) Phase 1: Planning and preparation activities, including the site characterization and hazardous material removal and disposal (meeting State of California requirements);
2) Phase 2: Perform dismantlement, decontamination and remediation activities; 16

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII packaging and disposal of radioactive waste; preparing the site for license termination; and

3) Phase 3: Complete the Final Status Survey and prepare the final reports to support termination of the license.

Phases 1 and 2 may have some overlap in order to take advantage of available resources, flatten waste volume shipment workload and meet the license termination time schedules. Details on the activities to be performed for each phase are presented below.

4.1.1 Phase 1, Planning and Preparation VNC is currently in the planning and preparation phase (Phase 1) to decommission the VBWR and EVESR. Scoping/characterization surveys, area classification, and Derived Concentration Guideline Levels (DCGL) development are being performed to support decommissioning activities and radiological assessment consistent with the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM). (5)

Building and land area surveys will determine the magnitude of contamination and help further delineate classification boundaries inside the areas of interest. These surveys will also assist in determining the dismantlement process and waste streams, i.e., decontaminate and re-cycle, dismantle and disposal of radioactive waste at an NRC-licensed disposal facility (both EnergySolutions in Clive, Utah and Waste Control Specialists in Andrews County, Texas are relevant to VNC radioactive and mixed wastes). Should other licensed disposal facilities become available in the future, VNC may elect to use them. Decisions for determination of disposal site selection will be based on waste classification, specific waste item risk evaluations, integrated cost, and other factors as determined by GEH management.

A thorough inspection is being performed and an inventory of hazardous materials is being prepared for VBWR and EVESR. Hazardous materials will be removed from the buildings, processed, treated, and disposed of as required. Mixed waste, being hazardous and radioactive, will be disposed of at a suitably licensed radioactive waste disposal site as identified in the above paragraph. Identified hazardous waste materials include lead, polychlorinated biphenyls, and asbestos.

Specific work plans will be prepared, reviewed, and approved for major decommissioning activities and specialty tasks as needed, such as the reactor vessel removal.

4.1.2 Phase 2: Dismantlement, Decontamination, and Remediation All decommissioning activities will be performed under the established GEH VNC programs, including:

VNC Health and Safety Program, 17

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII VNC Radiation Protection Program VNC Radioactive Waste Management Program VNC Quality Assurance Program The removal and disposal of the VBWR and EVESR reactor vessels, vessel internals, and other SSCs will be performed during Phase 2, followed by removal of contaminated concrete and associated materials as needed. Any identified areas/lands within and around the 300 Area identified as requiring remediation will be removed, packaged, and shipped for disposal. NOTE:

GEH does not intend to demolish buildings during decommissioning, unless determined necessary for meeting requirements of 10CFR 20, Subpart E.

During the decommissioning process, surveys and assessment will be performed, including radiological and hazardous to identified, categorized, and quantified. Surveys will be conducted for developing work controls and waste management. The information will be used in developing procedures to ensure the contaminated areas are removed and ensure that worker exposure is controlled.

As defined in 10 CFR 50.2, Definitions, a major decommissioning activity is any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than Class C waste in accordance with 10 CFR 61.55." Prior to starting a major decommissioning activity, the plant components will be radiologically surveyed, characterized, and decontaminated, as required, to minimize worker radiation exposure. Rigging, removal, handling and packaging, and other equipment necessary to remove and transport the components will be designed and procured.

For VBWR, major decommissioning activities include the removal of the reactor vessel and any permanent modification necessary to the containment structure during the dismantlement process.

These activities will be performed pursuant to 10 CFR 50.59.

For EVESR, major decommissioning activities include removal of the reactor vessel and related SSCs. Other decommissioning activities include decontamination and/or removal of the EVESR stack, decontamination of the control room, turbine, dump condenser and equipment building, and the underground piping and tunnel. Based on characterization surveys, surface soil in and around the 300 Area is not anticipated to require decontamination. Past sampling of groundwater has not identified contamination requiring remediation. Other than the underground piping and tunnel areas, there are no known areas with subsurface contamination.

All activities will be performed with controls to minimize any airborne radioactivity and control and liquid radioactive waste. All water existing or created during decommissioning activities will be controlled and processed on-site either for disposal as radwaste or processed through the on-site waste evaporator for volume reduction.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII All radioactive waste from the decommissioning is expected to be Class A waste, with the possible exception of reactor internal components which may be Class B. The VBWR vessel and internals have been characterized (8) as Class A waste as a whole. Some of the vessel internals are Class B.

GEH has determined that intact removal and disposal is the method for removal, thus the vessel and internals as a complete unit will be disposed as Class A. EVESR vessel is expected to be classified in a similar manner. Due to limited access to the EVESR vault, these components will be characterized as part of the removal process. No Class C or greater than Class C waste is anticipated.

All waste will be packaged and shipped in accordance with U.S. Department of Transportation requirements and disposed of at a licensed radioactive waste disposal site. No off-site processing is anticipated at this time. The transportation of decommissioning wastes (almost exclusively radiological and non-radiological) will involve no additional technical considerations beyond those for transportation of existing radioactive material in transit. Existing regulations covering transportation of radioactive material are covered under NRC regulations in 10 CFR Parts 20, 71, and 73, and Department of Transportation regulations in 49 CFR Parts 170-189. Radiological exposures associated with the shutdown reactors is relatively low, hence cask-type shipments are not anticipated.

Transportation via both highway and rail is expected, where the mode will be determined by the waste type, equipment availability and other relevant factors. VNC does not have on-site rail access so rail shipments would originate as truck shipments out of the VNC site to an as yet selected rail facility. Truck Shipments to Clive, Utah would likely travel via California and Interstate highways and ultimately across Interstate 80, whereas those traveling to Andrews County, Texas may travel via California highway 5 and Interstate 40. The distance by highway from VNC to Clive, UT is ~ 700 miles, whereas the distance to Andrews County, TX is ~1,400 miles. Distance traveled will have an impact on disposal site selection.

Some limited decommissioning activities, such as hazardous abatement, removal of small components and general debris may occur while some Phase 1 decommissioning planning activities are still on-going.

4.1.3 Phase 3, Final Status Surveys and License Termination Phase 3 activities will include performance of Final Status Survey (FSS) to confirm the licensed areas meet release criteria for license termination. The methodology of MARSSIM will be followed for the performance and assessment of these surveys. DCGLs will be established, and approved, to provide release criteria for building surfaces and soils as part of the development and approval of the LTP. A detailed FSS Plan will be developed to verify a final site radiological condition. Separate FSS Plans will be developed for VBWR and EVESR, reflecting the different completion dates.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII The VBWR license is limited to the containment (with all materials and components within) and its adjacent sump. All other structures, systems, components, including the stack and surrounding 300 Area grounds, fall under the EVESR license. Being on a shared site area (300 Area) and with EVESRs close proximity, ambient radiation levels in and around the VBWR licensed area may limit the ability to complete some final status surveys until completion of EVESR decommissioning.

The VBWR FSS will verify that any residual radioactive material will not pose a potential radiation dose to workers or public in excess of the 10 CFR 20, Subpart E, decommissioning dose criterion of 25 mrem per year, considering that VBWR remains bounded by the 300 Area which falls under the EVESR license. Any residual radioactive materials under the VBWR license that may remain following VBWR decommissioning will be transferred to the EVESR license and addressed as part of the EVESR FSS and license termination. The final 300 Area FSS will be performed following the EVESR decommissioning activities. The VBWR and EVESR and supporting facilities in the 300 Area will be decommissioned with FFS demonstrating compliance with dose standards of 10 CFR 20, Subpart E prior to final license termination of the EVESR DR-10 license, excepting those buildings / areas under the authority of the site broad-scope SNM-960 and / or California byproduct material 01-0017 licenses.

4.2 Schedule While the planning and preparation (Phase 1) is being performed for VBWR and EVESR at the same time (currently on-going), Phases 2 and 3 represent different schedules with VBWR being completed first, followed by EVESR. A schedule for the VBWR decommissioning is included in Table 4-1 below:

Table 4-1, VBWR Schedule Activity Start Completion Bioshield Removal & Asbestos Abatement June 2022 November 2022 The upper bioshield is removeable and is contaminated with asbestos. All of this bioshield will be removed, including the primary piping, and disposed at a licensed facility. Further, hazardous materials will be abated during this activity Reactor Vessel Removal November 2022 September 2023 The reactor vessel will be dispositioned via intact removal and disposal 20

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII RFPs have been submitted and upon receipt will be evaluated for decision under 50.59 review, then executed Other Dismantlement & Decontamination September 2023 September 2024 Various areas of surface contamination will require and April 2030 decontamination, including any activation remaining in the fixed bioshield.

Any other miscellaneous components with levels exceeding the DCGLs will be removed or decontaminated to below DCGLs.

Some of this work may be deferred to be combined with EVESR decontamination for efficiency following facility transfer to EVESR license LTP Development & Submittal November 2022 September 8, 2023 Final Status Survey (under EVESR license) September 2024 April 2030 License DPR-1 Termination September 8, 2025 21

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII The schedule for EVESR decommissioning is included in Table 4-2 below:

Table 4-1, EVESR Schedule Activity Start Completion Planning: July 2022 June 2027 Development/submittal of this LPSDAR Development of specifications, Request for Proposals (RFPs), receipt and evaluation of proposals and decision making for demolition options for remaining components Polar crane repair/replace evaluation Development of plans and procedures for execution of decommissioning activities Characterization of remaining components Dismantlement & Decontamination August 2023 April 2030 Polar Crane repair/replacement Hazardous materials abatement Removal of EVESR Vessel, internals and interferences through either segmentation or intact removal and disposal Removal of remaining SSCs including miscellaneous piping, vessels, valves, and tanks Concrete demolition to below DCGLs including activated portions of bioshield and other facilities within the 300 licensed Area Removal of any impacted soils as required Removal of any miscellaneous components as necessary to facilitate license termination LTP Development & Submittal July 2026 April 15, 2028 Final Status Survey April 2028 April 2030 License DR-10 Termination April 15, 2030 22

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII 5.0 PROJECT MANAGEMENT 5.1 Organization The decommissioning activities will be performed under the direction and oversight of GEH and VNC site management and programs, supplemented by contracted services as needed, e.g., reactor vessel removal. Staff will be trained as required to meet site and regulatory requirements. GEH VNC will conduct routine meetings for As Low As Reasonably Achievable (ALARA) and Safety reviews of decommissioning activities to ensure site goals and expectations are met. Quality Assurance Decommissioning will be performed under the existing NRC approved GE Hitachi Nuclear Energy Americas Quality Assurance Program Description (NEDO-11209-A, Revision 16) (Note - NRC approved this document on 1/22/21. NEDO-11209 replaced the VNC QAP). A Decommissioning Quality Assurance Project Plan will be developed, as needed, for defining and/or expanding the quality requirements for the decommissioning efforts.

5.1.1 Contractors Decommissioning tasks not performed by GEH employees will be performed by approved contractors. GEH may at their discretion retain companies to provide the resources for selected decommissioning-focused position (e.g., Safety), project (e.g., construction, assessment), and remediation. All contractors will be qualified, as determined needed, by evaluation by GEH.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII 6.0 Financial Assurance 6.1 Decommissioning Cost Estimate Two decommissioning cost estimates (DCE) estimates have been prepared for decommissioning the 1) VBWR and, 2) EVESR and other 300 Area structures to levels of radioactivity that are suitable for unrestricted release in accordance with the criteria for decommissioning in 10 CFR 20.1401 and 20.1402, and for NRC license termination pursuant to 10 CFR 70.38 to permit termination of respective NRC licenses DPR-1 and DR-10. The VBWR DCE details costs and labor for decommissioning work inside the VBWR reactor building. The EVESR DCE details costs and labor for inside the reactor building and the outside structures and areas contained within the 300 Area.

Both DCEs contain costs for insurances, permits, labor, equipment, material, and waste to support work during the 3 phases of decommissioning leading to license termination. Both DCEs were developed by escalation of the existing Decommissioning Cost Estimate being used to validate GEH accretions and bond values per the current GEH method of escalation.

The cost estimates for both VBWR and EVESR are contained in Appendix A. This information contains GEH Proprietary Information and will be withheld from public disclosure pursuant to 10 CFR 2.390.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII 7.0 ENVIRONMENTAL REVIEW 7.1 Radiological The environmental radiological impact for the decommission has been determined to be SMALL.

Due to limited quantities of radioactive materials and the low levels of activity, potential releases of radioactivity to the surrounding environment are considered minimal, well within the limits of 10 CFR 20. Decommissioning activities will be performed under the VNC Radiation Protection Program and in a manner that minimized potential for creating airborne activity and controls any liquid waste existing or generated.

7.1.1 Radiological Accident Analyses Table ES-1 of NUREG-0586, Final GEIS, (9) provides a summary of environmental impacts from decommissioning nuclear power facilities. Since all special nuclear material and used nuclear fuel have been removed prior to decommissioning, the only possible accidents are those characterized in NUREG-0586 as other radiological - (nonfuel) - related accidents which are identified in Table ES-1 as having a SMALL impact on the environment.

7.1.2 Radiological Environmental Monitoring GEH VNC conducts routine radiological environmental monitoring covering all operations at the VNC site. The program includes the routine collection of air samples, vegetation, soil and groundwater. Samples are analyzed for radioactivity and results evaluated to ensure any releases from the site are well within regulatory limits and ALARA. Dosimeters (TLDs/OSLs) are placed around the site to monitor ambient radiation levels and evaluate any increase attributable from facility operations. This program will continue during the decommissioning activities to verify that the decommissioning activities have little to no impact on the environment and public health and safety. VNC uses an established process to evaluate non-routine activities (e.g.,

decommissioning activities) and will evaluate the need to enhance monitoring requirements using best management practices and apply such measures in the project specific plans as identified.

GEH concludes that the radiological impacts of decommissioning activities at the VNC are bounded by those in the decommissioning GEIS / prior environmental assessments. Impact is categorized as SMALL.

7.2 Non-Radiological The decommissioning activities described in Section 4.0 are not anticipated to require activities, techniques, or methods beyond those considered by NRC in the Decommissioning GEIS, NUREG-0586. (9) In the Decommissioning GEIS, NRC issued generic determinations for all the environmental issues with the exceptions of threatened and endangered species and environmental 25

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII justice, which require site-specific assessments. Site-specific assessments are also required for land use when offsite areas are needed to support decommissioning, and terrestrial ecology, aquatic ecology, and cultural resources when decommissioning activities are planned for areas outside of the operational area.

For the purposes of assessing decommissioning impacts, NRC defines operational areas in the Decommissioning GEIS as the portion of the plant site where most or all of the site activities occur, such as reactor operation, materials and equipment storage, parking, substation operation, facility service, and maintenance. This includes areas within the protected area fences, the intake, discharge, cooling, and associated structures as well as surrounding paved, graveled, maintained landscape, or other maintained areas. The 997-acre VNC site property along with the 610 acre GEH property encompasses approximately 1,600 acres. The VNC Site Developed Area is 105.8 acres of the 1,600 acres. The VBWR and EVESR are located in the Building 300 Area. The VNC site also includes the Building 100 Area and Building 400 Area that host operations, maintenance, and administrative structures and activities. The other shutdown (test) reactor, GETR, is located in the Building 200 Area. During the operation and since the shutdown of VBWR and EVESR, they have been supported by the site for maintenance, material storage, staff offices, site infrastructure, parking, etc. Therefore, the operational area for decommissioning of VBWR and EVESR is the Site Developed Area. No offsite land is needed to support decommissioning.

All the decommissioning activities and supporting activities such as staging, managing equipment and waste, and decommissioning staff workspace and parking are anticipated to be confined to the VNC operational area (i.e., existing developed area of VNC). Primary decommissioning construction activities (e.g., dismantlement, excavation, staging, and decontamination) are anticipated to occur within or be localized around the Building 300 Area. Therefore, site-specific assessments for aquatic ecology, terrestrial ecology, and cultural and historic resources were not required. However, site-specific impact assessments are required for threatened and endangered species and environmental justice and were conducted by GEH.

The levels of significance assigned to site-specific environmental impacts are classified as small, moderate, or large, as defined by NRC in the Decommissioning GEIS. The following is a summary of the reasons for reaching the conclusion that the non-radiological environmental impacts of decommissioning VBWR and EVESR will not result in significant (i.e., MODERATE or LARGE) environmental impacts not previously reviewed.

As stated above, the decommissioning activities are anticipated to be confined within the Site Developed Area within the larger VNC site boundary. The Site Developed Area does extend to the border with State Road 84; however, the dismantlement and decontamination activities will be away from any site borders. The nearest residential property to the operational area is located approximately 300 feet south of the VNC access gate across Highway 84. The nearest residential property to the VBWR/EVESR area is located approximately 2,600 feet to the Site Developed 26

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Area fence line from the west. Noise or other physical effects such as dust from decommissioning activities or changes in the viewshed are not expected to have significant offsite impacts.

The majority of the waste from decommissioning will be radioactive waste. The management and transport of radioactive waste is discussed above in Section 4.1. The smaller quantities of hazardous and non-hazardous waste will be managed in accordance with state regulations and disposed of in permitted offsite facilities. The management and disposal of non-radiological waste from decommissioning will have a SMALL impact.

In addition to potential radiological impacts of transportation, Section 4.3.17 of the Decommissioning GEIS recognizes non-radiological impacts of transportation to include increased traffic, wear and tear on area roadways, and increased traffic accidents from both radiological and non-radiological waste transport. NRC concluded that transporting materials to and from a decommissioning site will not significantly impact the overall traffic volume or compromise the safety of the public. GEH's waste shipments are not expected to be large enough in number to have a detectable or destabilizing effect on traffic flow or road wear. The additional number of workers during the decommissioning is expected to be less than 30. Impacts to the existing transportation infrastructure will be SMALL.

Decommissioning activities include excavation and GEH anticipates the need for filling excavations with clean backfill. This clean fill may be supplied by commercial vendors from offsite borrow areas approved for that land use. GEH will comply with state and local regulations regarding the use of fill materials.

Maintenance and surveillance activities to support the shutdown status of the VBWR and EVESR require small quantities of water. Decommissioning activities will increase water use for VBWR and EVESR for such activities as dust abatement during soil excavation and management, water-based decontamination activities, equipment rinsing, and staff support. These water uses will be supplied by the existing VNC potable water supply and GEH will ensure that water use is within existing water rights/allocations and withdrawal permits. Wastewater streams created from these water uses will be managed and treated within existing VNC wastewater infrastructure and in accordance with their permits.

Decommissioning activities with potential for impacting surface water quality include decontamination and dismantlement activities and wastewater will be collected and treated within existing VNC infrastructure. Stormwater runoff from structure dismantlement areas and accidental releases (spills) are also potential sources of pollutants entering surface waters during decommissioning. VNC will continue to manage stormwater in accordance with its existing infrastructure, permits, and Best Management Practices (BMPs). The existing spill control and prevention practices and procedures will also remain in place and be modified as necessary for decommissioning activities. Any land-disturbing activities will be conducted in accordance with BMPs for soil management and in accordance with state and local erosion control and sediment 27

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII permits and regulations. In addition, Clean Water Act Section 404 permits will be obtained if required.

Any groundwater encountered during excavation or piping removal activities will be collected and characterized as appropriate to ensure proper management of the removed groundwater.

Additionally with respect to groundwater, the GEIS noted that demolishing concrete structures and storing rubble on site could result in changes (higher alkalinity) in local water chemistry, but the non-radiological effects of such changes on water quality is nondetectable offsite at all nuclear power plants. Furthermore, NRC noted in the GEIS that the Resource Conservation and Recovery Act (RCRA) will apply to concentrated subsurface placement of demolition debris, which will limit water quality effects from using rubble and soil as fill material. GEH will not use rubble for fill material in compliance with California Governors Executive Order D62-02.

Active groundwater remediation at the VNC is not suggested by annually reported routine groundwater monitoring data, which is orders of magnitude below Environmental Protection Agency (EPA) drinking water standards.

The GEIS identified decommissioning activities that may affect air quality, including worker transportation to and from the site, dismantling of systems and removal of equipment, movement, and open storage of material onsite, demolition of buildings and structures, shipment of material and debris to offsite locations, and operation of concrete batch plants. Decommissioning plans for VBWR and EVESR may, to a very limited extent, involve all these activities with the exception of operation of a concrete batch plant. The potential for non-radiological air quality impacts at VNC could primarily stem from fugitive dust and equipment and vehicle emissions. GEH will conduct decommissioning activities in accordance with state and local air quality regulations and equipment will be properly permitted and operated with the appropriate emission controls.

As presented above, decommissioning activities are anticipated to be confined to developed areas and soil excavation is anticipated to be specifically within the Building 300 Area. The other decommissioning activities will utilize existing structures and impervious surfaces. Thus, the potential for directly impacting terrestrial habitat is minimal. The noise and dust from decommissioning activities could indirectly impact nearby terrestrial habitat. However, decommissioning activities will be confined to the operational area, and with the implementation of dust control and noise attenuation, the effects, if any, will be minimal and temporary. Therefore, impacts to terrestrial ecology will be SMALL. As presented above, wastewater and runoff will be managed with existing VNC systems and procedures will be used to prevent and control accidental releases and spills. Thus, any impacts to aquatic ecology will also be SMALL.

The ongoing maintenance and surveillance activities at the shutdown VBWR and EVESR reactors have assigned staff. Workforce reduction at VNC, if any, as a result transitioning the reactors from shutdown to decommissioning and completion of decommissioning will be SMALL. This transition is also not expected to impact VNCs tax liability.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII GEH will self-perform and/or engage a qualified contractor(s) to conduct decommissioning activities with strict adherence to NRC and both Federal and State of California OSHA safety standards, practices, and procedures. As shown in Section 4, dismantle, removal, and decontamination activities will commence in 2022 and conclude in 2030. Decommissioning staff is expected to peak at less than 30 workers and occur 2023 -2027. This small decommissioning workforce will have zero to SMALL impact, both adverse due to demand for community services or beneficial due to workers wages and spending, on the local socioeconomic conditions.

Section 4.3.14 of the Decommissioning GEIS determined that potential effects of decommissioning on cultural, historical, and archaeological resources will be SMALL for all plants when the decommissioning activities are confined to the operational area. The decommissioning activities for VBWR and EVESR will be confined to the operational area. GEH also intends to avoid ground disturbances where extensive construction activity has not previously occurred and backfill will be sourced from offsite, minimizing the potential for any inadvertent discovery of an archaeological site. As discussed above, the decommissioning activities will take place away from the site borders and thus cultural or historic sites in the area surrounding the VNC site are not expected to be impacted by the temporary decommissioning activities.

In Section 4.3.14.2 of the GEIS, NRC noted the potential for the nuclear facility itself to be potentially eligible for inclusion in the National Registry of Historic Places (NRHP), especially as it is older than 50 years and represents a significant historic or engineering achievement. VBWR has the distinction of holding license DPR-1, the first issued DPR license. Based upon research conducted to date, VBWR appears significant under NRHP Criterion A, Invention, for furthering the development of nuclear technology. The reactor was constructed in 1956 as part of the first privately funded nuclear power plant that was capable of producing megawatts of electricity to a public power grid. The reactor was a collaboration between the GE and the Pacific Gas and Electric Company (PG&E). The reactor supplied approximately 40,000 megawatt hours of electricity to the Bay Area between October 1957 and December 1963. VBWR also appears to possess significance under NRHP Criterion C for engineering as an early facility that managed materials and equipment in order to produce megawatts of electricity. Additionally, the design of the Vallecitos reactor was a pioneering example that operating conditions could be achieved at all sizes. VBWR appears to retain sufficient integrity to convey significance under Criteria A and C and is likely eligible for listing in the NRHP.

Preliminary research indicates that the EVESR reactor is not individually significant. EVESR was constructed to develop nuclear superheat, but research did not reveal any significant events related to EVESR that may make the reactor significant on its own. However, there is potential that EVESR could contribute to a potential historic district. Though not fully reviewed as part of the current survey, research suggests that the VNC campus is potentially eligible for listing in the NRHP under Criterion A as a district. Significance of a potential district is related to VNCs status as the first privately funded nuclear facility to operate with two of the first issued licenses under 29

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII the AEC formed under the Atomic Energy Act: Developmental Power Reactor-1 (DPR-1) and Test Reactor-1 (TR-1). VNC may also possess significance under Criterion C as a district with a concentration of intact mid-century modern office buildings. Further study is required to determine if EVESR could potentially be NRHP-eligible as a contributing element to a historic district.

7.2.1 Threatened and Endangered Species A review was performed for identifying threatened and endangered (T&E) species for the local area and any potential impact that could result from the decommissioning activities. On August 11, 2022, biologists and ecologists conducted a habitat assessment and wetland delineation of the operational area, an approximately 106acre parcel considered the Site Developed Area, to evaluate baseline biological conditions.

Based on the review, eight special-status plant and 24 wildlife species were considered to have potential to be present within the operational area. The Biological Resources Report (10) presents an assessment of the likelihood for these special-status species and their habitats to occur in the operational area. Based on the onsite habitat conditions, there are five specialstatus species that have a moderate or moderate/high potential to occur:

California redlegged frog (Rana draytonii), Federally Threatened, Species of Special Concern California tiger salamander (Ambystoma californiense), Federally Threatened, State Threatened San Francisco dusky-footed woodrat (Neotoma fuscipes annectens), State Species of Special Concern Western pond turtle (Emys marmorata), State Species of Special Concern Pallid bat (Antrozous pallidus), State Species of Special Concern The operational area is primarily nonnative/ruderal grassland habitat. Conclusions of the completed surveys indicate rare plants are not expected to occur within the operational area.

Critical habitat for federally listed species is also not present within the operational area. Due to the highly disturbed nature of the operational area, its location within an urbanized landscape, and lack of recent occurrences, no state or federally listed wildlife species are expected to be directly impacted. However, the five special-status species listed above and nesting birds protected under the federal Migratory Bird Treaty Act and California Fish and Game Code may occur within the project boundary. Avoidance and Minimizations Measures (AMMs) prescribed in the Biological Resources Report will reduce the potential for adverse effects on these special status species and aquatic resources during Project construction activities.

7.2.2 Environmental Justice 30

Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII GEH has assessed the concerns of environmental justice as it relates to the effects of VBWR and EVESR decommissioning. GEH examined the geographic distribution of minority and low-income populations within a 50-mile radius of the VNC site using the US Census Bureau (USCB) 2020 Redistricting Data (PL 94-171) for minority populations and the USCB 2020 American Community Survey 5-year estimates for low-income populations. Minority populations are disbursed throughout the region. Low-income populations are sparse and concentrated in cities.

None of the locations of identified low-income minority populations when considered in the context of impact pathways described in this section are expected to be disproportionately impacted.

The identified minority populations closest to the VNC site are located approximately 1.8 miles from the plant in USCB Block Group 060014507011. In 2020, the block group contains an Asian population and an Aggregate and Hispanic population. (11) (12) The closest low-income block group that meets the guidance criteria for both individuals or families, using the region as the geographic area for comparison, is located 3.9 miles north of the VNC site (Block Group 060014507411). (11)

GEH determined that impacts from decommissioning activities to all resource areas will be SMALL. No disproportionately high and adverse impact or effects on members of the public, including minority and low-income populations, are expected to result from the decommissioning of VBWR and EVESR.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII 8.0 References

1. U.S. Nuclear Regulatory Commission. Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report.
2. U. S. Nuclear Regulatory Commission. NRC letter, "GE Hitachi Nuclear Energy, Vallecitos Nuclear Center - Response to the Description for Decommissioning the Shutdown Reactors". NRC April 8, 2022 letter, Roberts to Feyrer. (ADAMS Accession No. ML22066A569).
3. GE Hitachi. GE Hitachi Nuclear Energy Description of Process for Decommissioning the Vallecitos Nuclear Center Shutdown Reactors (ADAMS Accession No. ML21315A005). November 11, 2021.
4. NRC. GE Hitachi Nuclear Energy, Vallecitos Nuclear Center Shutdown Reactors - Acceptance of Request to Withdraw Exemption Request for Alternate Decommissioning Schedule (ADAMS Accession No. ML21258A042). October 12, 2021.
5. . NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).

Revision 1. August 2000.

6. Stantec Consulting Services, Inc. Phase I Environmental Site Assessment for the Vallecitos Site. Sunol, California : s.n., November 19, 2019.
7. NRC. Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1. s.l. : NUREG-0586, Supplement 1, Volume 1, 2002.
8. DW James Consulting. Vallecitos Nuclear Center VBWR Reactor Vessel and Internals Characterization and Classification. 2022.
9. U.S. Nuclear Regulatory Commission. Final Generic Environmental Impact Statement on Decommissioning of Power Reactors - Excerpted Sections Relating to Power Reactors. 1988.
10. Gaber, Christine. Biological Resources Report. Rancho Cordova : Kleinfelder, 2022.
11. U.S. Census Bureau. Census - Geography Profile Block Group. Livermore and Sunol : U.S.

Census Bureau, 2020.

12. . Census - Geography Profile State. Livermore and Sunol : US Census Bureau, 2020.
13. American Society of Mechanical Engineers. An International Mechanical Engineering Landmark: The Valecitos Boiling Water Reactor. [Online] October 7, 1987. [Cited: December 23, 2021.] https://www.asme.org/about-asme/engineering-history/landmarks/128-vallecitos-boiling-water-reactor.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Appendix A Decommissioning Cost Estimates A1.1 VBWR The VBWR total DCE is $16,216,000 with a low range of $12,973,000 and high range of

$16,216,000. Table A-1 provided the breakdown of estimated costs.

Table A-1 VBWR DCE Breakdown Estimated Cost Category ($K)

Planning and Preparation Redacted Decontamination and Redacted Dismantlement Release Survey Redacted Waste Packing and Shipping Redacted Waste Disposal Redacted Equipment/Supplies Redacted Laboratory Costs Redacted Utilities/Shared Services Redacted NRC Inspection Redacted Subtotal Redacted 25% Contingency Redacted Total $16,216 A1.2 EVESR The EVESR and 300 Area outside structure total DCE is $16,901,000 with a low range of

$13,520,000 and high range of $16,901,000. Table A-2 provides the breakdown of estimated costs.

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Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report, Rev. XII Table A-2 EVESR & 300 Area DCE Breakdown Estimated Cost Category ($K)

Planning and Preparation Redacted Decontamination and Redacted Dismantlement Release Survey Redacted Waste Packing and Shipping Redacted Waste Disposal Redacted Equipment/Supplies Redacted Laboratory Costs Redacted Utilities/Shared Services Redacted NRC Inspection Redacted Subtotal Redacted 25% Contingency Redacted Total $16,901 A1.3 Surety Method Financial assurance for decommissioning costs is provided by GEH using payment surety bonds.

The decommissioning cost for the VBWR, EVESR and the balance of the 300 area is estimated to be between $26,493,000 and $33,117,000.

The decommissioning costs identified in this appendix are 0.3% higher for VBWR, and 2.8%

higher for EVESR than the current bond amounts issued in March 2022 (based on December 31,2021 cost estimates). The decommissioning bond amounts are increased by 4% (on the end of year cost estimates) annually.

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