ML24318C254
| ML24318C254 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/18/2024 |
| From: | Reactor Decommissioning Branch |
| To: | |
| Shared Package | |
| ML24318C248 | List: |
| References | |
| Download: ML24318C254 (1) | |
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Enclosure Environmental RAI-01 Please provide an updated Supplemental Environmental Report which includes potential impacts of the proposed action that are beyond the scope of what has previously been considered in the Environmental Assessment for the License Termination Plan at Fort Calhoun (ML23333A049).
The supplemental environmental report should include, at a minimum, potential impacts to groundwater, public and occupational health, soils/geology, and land use, along with consideration of the no-action alternative. Any environmental resource areas that would not be affected by the proposed action can cite previously published environmental assessments, if the affected environment and potential impacts to the environment remain unchanged.
Discussion:
In its June 2024, License Amendment Request (LAR) to Revise License Termination Plan (LTP), the Omaha Public Power District (OPPD) states that the proposed license amendment to the license termination plan for the Ft. Calhoun Station Unit 1 located in Washington County, Nebraska, should be categorically excluded. The NRC staff has evaluated OPPDs proposal and determined that an Environmental Assessment (EA) should be prepared.
In Section 5 Environmental Consideration of Attachment 1 Fort Calhoun Station License Amendment Request to Revise the License Termination Plan, the applicant stated that the proposed action meets the requirements for a categorical exclusion as defined in 10 CFR 51.22(c)(9). OPPD claims the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed action fits under 10 CFR 51.22(c)(9).
The NRC staff reviewed the proposed action and determined the proposed action is not appropriate for a categorical exclusion under 10 CFR 51.22(c)(9) because the proposed action does not meet the criteria in 10 CFR 51.22(c)(9) or 10 CFR 51.22(c)(9)(ii). Specifically, 10 CFR 51.22(c)(9) is a categorical exclusion for ground disturbing activities within the restricted area (i.e., previously disturbed land) or for changes to surveillance and inspection requirements. The proposed action does not fit the first half of the cited regulation as the action is not altering a requirement related to installation or use of facility components and does not fit the second potential categorical exclusion because the proposed action is not altering how surveillance and inspections are done but would alter the end-state conditions of the site and is a more significant change to the inspection requirements. 10 CFR 51.22(c)(9)(ii) requires there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite and is not applicable because the proposed change has the potential to alter impacts to site groundwater after license termination, and by extension the potential public health impacts at the site after license termination. The proposed change would alter the approved site-specific DCGLs for soil deeper than three meters, which would allow OPPD to leave buried on site more radioactive material than initially considered in the approved LTP.
While the proposed action includes additional changes to the LTP aimed at limiting or preventing any release of the buried material into the groundwater, the changes in DCGLs do constitute a change in potential impacts beyond what was considered in the initial LTP review. A change to the end-state conditions of the site beyond what the NRC has previously reviewed requires an appropriate environmental review to provide reasonable assurance of adequate protection of public health and safety and to protect the environment.
2 Note that the since the proposed action does not meet any requirements under 10 CFR 51.20 for the preparation of an Environmental Impact Statement the NRC staff conclude an environmental assessment under 10 CFR 51.21 is the most appropriate environmental evaluation for this license amendment request.