ML24270A224

License Amendment Request - Historic and Cultural Resources Review Vallecitos Boiling Water Reactor and General Electric Test Reactor

ML24270A224
Person / Time
Site:	Vallecitos Nuclear Center, Vallecitos
Issue date:	09/26/2024
From:	Self L NorthStar Vallecitos
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML24270A223	List: ML24270A224
References
NSV 24-003
Download: ML24270A224 (1)

Text

NorthStar Vallecitos, LLC 6705 Vallecitos Rd.

Sunol, CA 94586 www.northstar.com

Sensitive Information Notice Luke M. Self The Enclosure to this letter contains confidential archeological site information and Vice President, NorthStar Vallecitos should not be made available for public dissemination. The authority for this 10 CFR 50.90 confidentiality is found at Section 304 of the National Historic Preservation Act of 1966. 10 CFR 50.82(a)(6)

Upon removal of the Enclosure, the balance of this letter may be made public.

NSV 24-003

September 26, 2024

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

License Amendment Request - Historic and Cultural Resources Review Vallecitos Boiling Water Reactor and General Electric Test Reactor Docket Nos. 50-18 and 50-70 License Nos. DPR-1 and TR -1

REFERENCE:

NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors, Supplement 1, dated November 2002 (ML023470304).

Dear Sir or Madam:

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," and consistent with the requirements of 10 CFR 50.82(a)(6) and the guidance set forth in NUREG-0586 ("Decommissioning GEIS," Reference), NorthStar Vallecitos LLC is submitting this License Amendment Request for Nuclear Regulatory Commission (NRC) review of major decommissioning activities, as defined in 10 CFR 50.2, that could diminish the historic integrity (e.g., physical demolition) of sele ct Vallecitos Nuclear Center (VNC) structures deemed potentially eligible for placement on the National Register of Historic Places (NRHP). Physical demolition of the VNC structures (i.e.; Vallecitos Boiling Water Reactor and General Electric Test Reactor) deemed potentially eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS with regard to cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO.

This License Amendment Request is intended to support applicable historic and cultural reviews regarding the NRHP potentially eligible structures in anticipation of the eventual and necessary physical demolition of the entire VNC site.

NSV 24-003 / Page 2 of 2

The enclosure to t his letter contains sensitive information which should be withheld from public disclosure. When separated from the Enclosure, this cover letter and Attachment are decontrolled.

This letter contains no new regulatory commitments.

In accordance with 10 CFR 50.91(b)(1), a copy of the publicly available portions of this letter has been provided to the State of California.

Should you have any questions concerning this letter, or require additional information, please contact Mr. Thomas B. Silko at (802) 451-5354, Ext 2506.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Sincerely,

9/26/24 SignatureSignature Executed On (Date)

Luke M. Self, Vice President, NorthStar Vallecitos

Attachment:

License Amendment Request - Historic and Cultural Resources Review Vallecitos Boiling Water Reactor, General Electric Test Reactor.

Enclosure:

Architectural History Survey at Vallecitos Nuclear Center, prepared by SEARCH, November 2022.

cc: Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555

Regional Administrator, Region 4 U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, Texas 76011-4511

Radioactive Materials Licensing Section, Radiologic Health Branch, California Department of Public Health NSV 24-003 Docket Nos. 50- 18 & 50-70

Attachment

Vallecitos Boiling Water Reactor General Electric Test R eactor

License Amendment Request - Historic and Cultural Resources Review Vallecitos Nuclear Center (10 pages excluding this cover sheet)

NSV 24-003 / Attachment / Page 1 of 10

License Amendment Request Historic and Cultural Resources Review Vallecitos Nuclear Center

1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, and consistent with the requirements of 10 CFR 50.82(a)(6)(ii) and the guidance set forth in NUREG-0586 ("Decommissioning GEIS," Reference 1 ), NorthStar Vallecitos LLC (NSV) is submitting this License Amendment Request (LAR) to request Nuclear Regulatory Commission (NRC) review of major decommissioning activities, as defined in 10 CFR 50.2, that could diminish the historic integrity (e.g., physical demolition) of the structures potentially deemed eligible for the National Register of Historic Places (NRHP) by the California State Historic Preservation Office (SHPO). Physical demolition of the structures deemed potentially eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS regarding cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO1. This LAR is intended to support applicable historic and cultural reviews regarding the NS owned NRHP potentially eligible buildings in anticipation of the eventual and necessary physical demolition of the VNC site. The five Vallecitos Nuclear Center (VNC) NRC Licenses were approved for transfer from GE-Hitachi Nuclear Energy Americas, LLC (GEH) to NSV on April 25, 2024 (Reference 2).

2.0 DETAILED DESCRIPTION AND BASIS FOR THE CHANGE VNC Background Information

Completed VNC environmental, historic, and cultural efforts include the following.

A Limited Post-Shutdown Decommissioning Activities Report (LPSDAR) was submitted in September 2022 for the Vallecitos Boiling Water Reactor (VBWR) and Vallecitos Experimental Superheat Reactor (EVESR) licenses. The LPSDAR (Reference 3) included an Environmental Review along with a Biological Resources Report.

A License Termination Plan (LTP) for the VBWR was submitted in September 2023. This LTP (Reference 4) in cluded an Environmental Report, prepared by Surf to Snow Environmental Resource Management, which summarizes Cultural and Historic resources. It is noted that the VBWR LTP Environm ental Report was updated by a supplement dated August 7, 2024 (Reference 5).

An Architectural Historical Survey was completed in November 2022 and has been provided as an Enclosure to this forwarding letter. The scope of this document covered the General Electric Test Reactor (GETR) 200 Area and the VBWR and EVESR 300 Area. The conclusion of this document was that while the loss of integrity at the 200 series and 300 series building complexes (30% and 69% of original buildings non extant, respectively) would likely preclude those areas from recommendation as a standalone historic district, the VBWR and GETR containment buildings were recommended as eligible for listing in the NRHP under C riteria A for their respective roles in the advancement of nuclear technology.

1 The Decommissioning GEIS states: "In a few situations, the nuclear facility itself could be potentially el igible for inclusion in the National Register of Historic Places, especially if it is older than 50 years and represents a significant historic or engineering achievement. In this case, appropriate mitigation would be developed in consultation with the SHPO." (Reference 1)

NSV 24-003 / Attachment / Page 2 of 10

In October 2022, NRC requested a Section 106 review with regard to the Nuclear Test Reactor (NTR) R-33 license renewal application (Reference 6). The NRC has determined that there would be no adverse effect on historic properties located near the NTR because of the proposed license renewal. As part of the State of California SHPO review for the NTR license renewal, the state identified that the nearest historic property is the Niles Canyon Transcontinental Railroad Historic District, located approximately 1.9 miles away.

In July 2023, Montrose Environmental performed a Cultural Resources Screening 2. Montrose prepared this cultural resource initial screening analysis to (1) identify the baseline environmental conditions for cultural resources in the VNC operating area; (2) inform the environmental reports that were prepared to address the guidance of the NRCs NUREG-1537 and Regulatory Guide 1.179; and (3) recommend additional study required to comply with National Environmental Policy Act and Section 106 of the National Historic Preservation Act. The background research consisted of a records search and literature review at the Northwest Information Center (NWIC),

archival map review, and geological map review.

Montrose Environmental conducted a cultural resources records search of the VNC on June 8, 2023, at the NWIC of the California Historical Resources Information System to identify previous cultural resource studies and records for the VNC and vicinity (NWIC File #22-1913). The NWIC, an affiliate of the Office of Historic Preservation, is the official state repository of cultural resource records and reports for Alameda County. The search consisted of a review of records for built-environment resources as well as archaeological resources within 0.25 miles of the VNC.

The results of the NWIC records search indicate that no known and previously recorded archaeological resources are located in the VNC. Archival maps indicate that the VNC was undeveloped until the 1950s, the decade within which the VNC was constructed; therefore, it is unlikely that any historic-period archaeological deposits are located within the VNC operating area.

In addition, based on the geoarchaeological review, the sensitivity of the area for buried pre-European contact archaeological deposits is low. The historic -period of the VNC site was documented and evaluated in 2016 as part of the State Highway 84 Widening Project. That evaluation concluded that the VNC appears eligible for inclusion in the NRHP based on the significance of the facilitys contribution to the scientific and technological development of nuclear power generation. Therefore, the VNC appears to be eligible for inclusion in the NRHP under Criterion A of the NRHP in the categories of Industry and Science at a national level and q ualifies as a potential historic property per the definition at 36 CFR Part 800.16(l)(1).

Under most circumstances, alteration of a property, including hazardous material remediation that is not consistent with the Secretary of the Interior's Standards for the Treatment of Historic Properties (36 CFR part 68) and applicable guidelines, would function to degrade a historic property's overall integrity. The removal, dismantlement, and disposal of contaminated, radioactive mechanical systems and components, as well as the eventual physical demolition of the facility, is imperative to protection of public health and safety and maintaining environmental welfare, and there is no viable alternative to decommissioning that achieves this goal.

Remediation and radiologically contaminated equipment removal activities were performed in VBWR and EVESR in 2007 and 2008 under the GEH Liability Reduction program, and the VBWR Reactor Vessel was removed in 2023.

2 Please refer to Appendix A of the Environmental Review submitted as part of Reference 4.

NSV 24-003 / Attachment / Page 3 of 10

NSV Historic Preservation Stewardship NSV is committed to continued stewardship of VNC historic and cultural resources through preservation of knowledge as well as models or artifacts of interest deemed acceptable for unconditional release in accordance with the VNC Radiation Protection Program. NSV recognizes its responsibility to ensure that the unique historic record of the VNC Site is sufficiently captured.

NSV will readily solicit consultation to provide guidance for monitoring and protecting VNC historic and cultural resources. NSV recognizes that if there is a potential to cause an adverse effect, as described in 36 CFR 800.5(a)(1), the SHPO will be contacted to determine if any special protection measures should be incorporated into planning the decommissioning activity in order to mitigate the potential for the adverse effect.

3.0 TECHNICAL EVALUATION

Physical demolition of the VNC structures deemed potentially eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS regarding cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO. As stated in the Decommissioning GEIS:

"Impacts to cultural, historical, or archaeological resources are considered detectable if the activity has a potential to have a discernable adverse affect on the resources. The impacts are destabilizing if the activity would degrade the resource to the point that it would be of significantly reduced value to the future generations, such as physically damaging structures or artifacts or destroying the physical context of the resource in its environment."

(pg. 4-67) 10 CFR 50.82(a)(6)(ii) states:

"Licensees shall not perform any decommissioning activities, as defined in § 50.2, that result in significant environmental impacts not previously reviewed."

Demolition of an NRHP-eligible structure qualifies as a reasonably foreseeable adverse effect, as described in 36 CFR 800.5(a)(1), which must be appropriately mitigated. Therefore, NSV is submitting this LAR to support applicable historic and cultural reviews regarding the VNC NRHP-eligible structures in anticipation of the eventual and necessary physical demolition of the facility to be performed in as part of the VNC decommissioning project. The removal, dismantlement, and disposal of contaminated, radioactive mechanical systems and components, as well as the eventual physical demolition of the facility, is imperative to protection of public health and safety and maintaining environmental welfare, and there is no viable alternative to decommissioning that achieves this goal.

4.0 REGULATORY EVALUATION

4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA This license amendment has been evaluated to determine whether applicable regulations and requirements continue to be met. NSV has determined that the proposed change would not require any exemptions or relief from regulatory requirements.

10 CFR 50.82, Termination of License 10 CFR 50.82(a)(6)(ii) states:

"Licensees shall not perform any decommissioning activities that result in significant NSV 24-003 / Attachment / Page 4 of 10

environmental impacts not previously reviewed."

VNC site decommissioning activities are not anticipated to require activities, techniques, or methods beyond those considered by NRC in the Decommissioning GEIS. Physical demolition of VNC structures deemed potentially eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS with regard to cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO.

Therefore, NSV is submitting this LAR to support applicable historic and cultural reviews regarding VNC structures NRHP-eligible buildings in anticipation of the eventual and necessary physical demolition of the facility.

36 CFR 800, Protection of Historic Properties The requirements of the Section 106 process are outlined in 36 CFR 800, Protection of Historic Properties, under the National Historic Preservation Act.

36 CFR 800.1(a) states:

Section 106 of the National Historic Preservation Act requires Federal agencies to take into account the effects of their undertakings on historic properties and afford the [Advisory Council on Historic Preservation (ACHP)] a reasonable opportunity to comment on such undertakings. The Section 106 process seeks to accommodate historic preservation concerns with the needs of Federal undertakings through consultation among the agency official and other parties with an interest in the effects of the undertaking on historic properties, commencing at the early stages of project planning.

Per 36 CFR 800.16(1)(1), Historic property means any prehistoric or historic district, site, building, structure, or object included in, or eligible for inclusion in, the NRHP maintained by the Secretary of the Interior. Per 36 CFR 800.16(1)(2), the term eligible for inclusion in the National Register includes both properties formally determined as such in accordance with regulations of the Secretary of the Interior and all other properties that meet the National Register criteria.

The VBWR and GETR containment structures have been recommended as eligible for listing in the NRHP under C riteria A for their respective roles in the advancement of nuclear technology (Reference Enclosure to forwarding letter).

10 CFR 50.51, "Continuation of License" 10 CFR 50.51(b) states:

"(b) Each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the NRC notifies the licensees in writing that the license is terminated. During such period of continued effectiveness, the licensee shall (1) Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility including, where applicable, the storage, control and maintenance of the spent fuel, in a safe condition, and (2) Conduct activities in accordance with all other restrictions applicable to the facility in accordance with the NRC regulations and the provisions of the specific 10 CFR part 50 license for the facility."

NSV will continue to conduct activities in accordance with the License until notified in writing by the NRC that the License is terminated.

NSV 24-003 / Attachment / Page 5 of 10

10 CFR 50.2, "Definitions" "Major decommissioning activity means, for a nuclear power facility, any activity that results in permanent removal of major radioactive components, permanently modifies the structure of containment, or results in dismantling components for shipment containing greater than class C waste in accordance with§ 61.55 of this chapter."

NSV will perform major decommissioning activities in accordance with this definition and as allowed by the Licenses. GEH has previously removed radiologically contaminated systems and components from the VBWR and GETR facilities.

4.2 NO SIGNIFICANT HAZARDS CONSIDERATION NSV has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1) Does the proposed amendment involve a significant increase in the probability or consequences of an unanticipated event previously evaluated?

Response: No.

This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that could diminish the historic integrity of select VNC structures. This license amendment will not affect operating procedures or administrative controls that have the function of ensuring the safe management of Special Nuclear Material or decommissioning of the facility. Therefore, the proposed change would not involve a significant increase in the probability or consequences of an unanticipated event previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any unanticipated event previously evaluated?

Response: No.

This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that could diminish the historic integrity of select VNC structures. This license amendment will not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases. Therefore, the proposed change would not create the possibility of a new or different kind of accident from any unanticipated event previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that could diminish the historic integrity of select VNC structures. This license amendment would not affect systems or components supporting source term reduction or decommissioning activities, nor would it result in a change in initial conditions or any other parameter affecting decommissioning activity accident analyses.

Therefore, this LAR does not involve a significant reduction in a margin of safety.

NSV 24-003 / Attachment / Page 6 of 10

4.3 CONCLUSION

S Based on the considerations discussed above: 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 2) such activities will be conducted in compliance with the NRC's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. NSV has concluded that the proposed license amendment supports a finding of no significant hazards consideration under the standards set forth in 10 CFR 50.92.

5.0 ENVIRONMENTAL CONSIDERATION

As stated above, the Decommissioning GEIS notes that if a nuclear facility itself is or could be potentially eligible for inclusion in the NRHP, appropriate mitigation would be developed in consultation with the SHPO. Under the National Environmental Policy Act, mitigation is determined through the Section 106 process, which seeks to accommodate historic preservation concerns with the needs of Federal undertakings through consultation among the agency official and other parties with an interest in the effects of the undertaking on historic properties. Impacts to cultural, historic, or archaeological resources are considered detectable if an activity has a potential to have a discernable adverse effect on the resources. The impacts are destabilizing if the activity would degrade the resource to the point that it would be of significantly reduced value to the future generations, such as physically damaging structures or artifacts or destroying the physical context of the resource in its environment (Reference 1).

Physical demolition of the VNC structures deemed potentially eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS regarding cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO and qualifies as a reasonably foreseeable adverse effect under 36 CFR 800.5(a)(1). This LAR requests NRC review of major decommissioning activities, as defined in 10 CFR 50.2, which could diminish the historic integrity of the VNC structures (i.e.;

VBWR and GETR containment removal by physical demolition) deemed potentially eligible for the NRHP by the SHPO. The removal, dismantlement, and disposal of these structures is planned for the reindustrialization of the property.

5.1

SUMMARY

OF ENVIRONMENTAL EFFECTS Aside from the cultural, historic, and archaeological resources impacts determination requested by the LAR, there are no other environmental resource areas impacted by the determination as to the buildings eligibility for the NHRP. However, since the NRC may evaluate other potential environmental impacts aside from the proposed action, a summary of the remaining environmental considerations is provided. This summary is a compilation of those environmental reviews provided in References 3 and 4.

5.1.1 LAND USE SMALL: The activities to prepare, remove, and dispose of the VNC structures and materials do not alter the land use of the existing site. Future demolition work will be performed inside the existing site operating area of the facility. There will be no need to utilize land outside of the existing VNC. Transport and disposal would use existing roads, highways and rail, and an existing approved LLRW disposal site.

Mitigation: None required.

NSV 24-003 / Attachment / Page 7 of 10

5.1.2 WATER USE SMALL: Water use during demolition activities to prepare, remove, and dispose of the VNC structures and materials is significantly less than that utilized during station operations and will be for a short duration. Water usage during demolition will come from the stations existing source.

Mitigation: None required.

5.1.3 WATER QUALITY SMALL: The majority of the demolition work on site will be performed on paved or graveled areas and not require ground disturbing activities. While the removal of select buried equipment will require ground disturbing activities, these activities will be limited to the VNC existing site operating area. The facility's existing system and plans would avoid inadvertent discharge in the event of a rainstorm.

Mitigation: None required.

5.1.4 AIR QUALITY SMALL: Equipment utilized to support the demolition of the site and removal of VNC materials will primarily use paved or graveled areas which do not generate fugitive dust. For activities which generate fugitive dust, dust control measures will be employed. Air quality during demolition from the vehicles for work and transportation is significantly less than during plant construction and operation.

Mitigation: In the event of equipment or vehicles use unpaved or non-graveled areas or when fugitive dust is being generated, dust control measures will be employed.

5.1.5 AQUATIC ECOLOGY SMALL: No direct impacts will occur to aquatic habitats. Although not anticipated, decommissioning activities could have a potential to indirectly impact aquatic habitats via stormwater runoff from structure dismantlement/decontamination and/or accidental releases (spills).

Mitigation: Best Management Practices (BMPs) and Avoidance and Minimization Measures (AMMs) will be implemented to the extent reasonable to mitigate any potential indirect impacts to aquatic features. Thus, potential impacts to aquatic ecology are considered small, temporary, and mitigatable.

5.1.6 TERRESTRIAL ECOLOGY SMALL: There were no direct or indirect impacts on native plants from the decommissioning activities as all work and equipment was confined to previously disturbed areas. There is a potential for project related activities to disturb nesting birds indirectly temporarily, however the impacts would be considered small, and can be further reduced through the implementation of AMMs.

Mitigation: Implement AMMs.

NSV 24-003 / Attachment / Page 8 of 10

5.1.7 THREATENED AND ENDANGERED SPECIES SMALL: The risk of impacting threatened or endangered species as a result of decommissioning activities is considered low. Impacts are considered small, temporary, and mitigatable.

Mitigation: With implementation of the AMMs, no detectable impacts (alterations to habitat or local population size, or direct mortality) are anticipated.

5.1.8 RADIOLOGICAL SMALL: VNC uses an established process to evaluate non-routine activities (e.g., decommissioning activities) and all activities will be performed under the VNC Radiation Protection Program. All nuclear fuel has been removed prior to decommissioning.

Mitigation: None required.

5.1.9 OCCUPATIONAL SMALL: Training and strict adherence to VNCs Health and Safety Program continues to protect workers from physical, chemical, ergonomic, and biological hazards.

Mitigation: None required.

5.1.10 SOCIOECONOMICS SMALL: The small workforce of approximately 40 personnel for the duration of demolition would not increase demand for community services or impact VNC's tax liability.

Mitigation: None required.

5.1.11 ENVIRONMENTAL JUSTICE SMALL: Locations of identified low-income populations are not near the VNC operational area; the closest low-income block group is located 3.9 miles north of VNC.

Mitigation: None required.

5.1.12 CULTURAL AND HISTORIC RESOURCES SMALL: The basis for this LAR is the potential impact to the two VNC structures deemed potentially eligible for the NRHP consideration.

Mitigation: To be determined as a part of this LAR processing.

5.1.13 AESTHETICS SMALL: The facility is distant from sensitive receptors located in a rural area of Alameda County in which there are minimal visual receptors, including highways and roads, residences, or sensitive receptors such as schools or parks. The landscape was previously altered by the construction of the facility, so decommissioning activities would return the landscape to that before the sites construction. Since the landscape will more likely resemble the natural look of the land prior to the facilities construction, there are zero to SMALL adverse impacts on aesthetics.

Mitigation: None required.

NSV 24-003 / Attachment / Page 9 of 10

5.1.14 NOISE SMALL: Noise generating equipment would typically operate during daytime working hours and only for the duration of demolition of larger structures and equipment. A significant amount of work would occur inside existing structures prior to any ones structures demolition. Noise level during operations would be within the U.S. Department of Housing and Urban Development guidelines.

Mitigation: None required.

5.1.15 TRANSPORTATION SMALL: The shipment of equipment, materials and workforce commute would be from nearby locations for a limited period and not significantly impact the overall volume of traffic or compromise the safety of the public.

Mitigation: None required.

5.1.16 IRRETRIEVABLE RESOURCES SMALL: The consumption of irreversible resources, such as fuel, oil, and lubricant, is for a short term and temporary. The consumption would less than that during the operation of the facility.

Mitigation: None required.

5.2 CRITERIA FOR A FINDING OF NO SIGNIFICANT IMPACT

1) There is reasonable assurance that the health and safety of the public will not be endangered by the decommissioning activity.

This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that c ould diminish the historic integrity of the VNC structures deemed eligible for the NRHP by the SHPO. The eventual physical demolition of the VNC facility is a necessary consequence of the decommissioning project and reuse of the property for industrial use. Therefore, there is reasonable assurance that the health and safety of the public will not be endangered by performance of the decommissioning activities described in this LAR.

2) There is reasonable assurance that such activity will be conducted in compliance with the Commission's regulations.

This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that c ould diminish the historic integrity of the VNC structures deemed potentially eligible for the NRHP by the SHPO. As stated above, NSV will perform major decommissioning activities in accordance with the 10 CFR 50.2 definition and as allowed by the License and will continue to conduct activities in accordance with the License until notified by the NRC in writing that the license is terminated. Therefore, there is reasonable assurance that the decommissioning activities as described in this LAR will be conducted in compliance with the Commission's regulations.

3) The issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

NSV 24-003 / Attachment / Page 10 of 10

This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that c ould diminish the historic integrity of the VNC structures deemed potentially eligible for the NRHP by the SHPO. Physical demolition is a necessary consequence of the decommissioning project, which is imperative for protection of public health and safety and maintaining environmental welfare. Therefore, the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

References:

1. NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors, Supplement 1, dated November 2002 (ML023470304).

2. Letter, USNRC to GEHA Regulatory Affairs., Order Approving T ransfer of the Vallecitos Nuclear Center Licenses and Conforming L icense A mendment (EPID L-2023-LLO-0002), dated April 25, 2024 (ML24039A 019)

3. Letter, M220122 from C. Martinez (GE Hitachi) to Document Control Desk (U.S. NRC), Vallecitos Nuclear Center Decommissioning Limited Post Shutdown Decommissioning Activities Report September 21, 2022.

(ML22264A324P ).

4. Letter, GEH to USNRC, Request for Termination of the Vallecitos Boiling Water Reactor License DPR-1, dated September 7, 2023 ( ML23250A267 and ML23250A268).

5. Letter, NorthStar Vallecitos, LLC to USNRC, Update to License Termination Plan for Vallecitos Boiling Water Reactor - Environmental Report, dated August 7, 2024 ( ML24220A200).

6. E-Mail, from D. Hardesty, NRC, to B. Greenaway, Office of Historic Preservation, October 27, 2022 (ML22325A352)

NSV 24-003 Docket Nos. 50- 18 & 50-70

Sensitive Information Notice This Enclosure contains confidential archeological site information and should not be made available for public dissemination. The authority for this confidentiality is found at Section 304 of the National Historic Preservation Act of 1966. Upon removal of t his Enclosure, the balance of this letter may be made public.

Enclosure

Vallecitos Boiling Water Reactor General Electric Test reactor

Architectural History Survey at Vallecitos Nuclear Center (105 pages excluding this cover sheet)