LIC-25-0001, Independent Spent Fuel Storage Installation - Response to Acceptance of Requested Licensing Action License Amendment Request to Revise the License Termination Plan (L-2024-LLA-0095)

Independent Spent Fuel Storage Installation - Response to Acceptance of Requested Licensing Action License Amendment Request to Revise the License Termination Plan (L-2024-LLA-0095)

ML25016A212
Person / Time
Site:	Fort Calhoun
Issue date:	01/16/2025
From:	Pearson B Omaha Public Power District
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-25-0001, EPID L-2024-LLA-0095
Download: ML25016A212 (1)

Text

U. S. Nuclear Regulatory Commission LIC-25-0001 10 CFR 50.90 10 CFR 50.82 LIC-25-0001 January 16, 2025 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station, Unit No. 1 Independent Spent Fuel Storage Installation NRC Docket No.72-054

Subject:

RESPONSE TO FORT CALHOUN STATION, UNIT NO. 1 ACCEPTANCE OF REQUESTED LICENSING ACTION RE: LICENSE AMENDMENT REQUEST TO REVISE THE LICENSE TERMINATION PLAN (L-2024-LLA-0095)

References:

1. Letter from USNRC to OPPD (T. Via), Fort Calhoun Station, Unit 1 - Issuance of Amendment to Renewed Facility License to Add License Condition to Include License Termination Plan Requirements (EPID L-2021-LIT-0000), dated January 31, 2024.

2. Letter from OPPD (A. Barker) to USNRC (Document Control Desk), License Amendment Request (LAR) to Revise License Termination Plan (LTP), dated June 18, 2024 (LIC-24-0007) (ML24177A132).

3. Letter from USNRC to OPPD (B. Pearson), Fort Calhoun Station, Unit No. 1 Acceptance of Requested Licensing Action Re: License Amendment Request to Revise the License Termination Plan (L-2024-LLA-0095), dated November 18, 2024.

By letter dated January 31, 2024 (Reference 1), NRC approved a License Amendment to add License Condition 3.D to include the License Termination Plan, Revision 1 for Fort Calhoun Station.

On June 18, 2024 (Reference 2) OPPD submitted a License Amendment Request to revise the License Termination Plan to include the ability to utilize grout as a mitigation measure in the dose modeling for Final Status Surveys. On November 18, 2024 (Reference 3), following the NRCs review process, the NRC accepted the Licensing Action request to revise the License Termination Plan. Within the acceptance letter a Request for Information was made to provide the Staff with information necessary to complete an environmental assessment.

The required additional information is contained in two attachments.

is the Request for Additional Information response. is the proposed revision to Chapter 8 of the License Termination Plan.

-~

Omaha Public Power District EMPLOYMENl WITH EQUAL OPPORTUNITY

U. S. Nuclear Regulatory Commission LIC-25-0001 There are no regulatory commitments contained within this letter.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Benjamin P. Pearson - Regulatory Assurance & Emergency Planning Manager at (531) 226-7249.

Respectfully, Benjamin Pearson Regulatory Assurance and Emergency Planning Manager BPP/bpp c: J. D. Parrott, NRC Senior Project Manager

2 Pages Follow Fort Calhoun Station Response to NRC Request for Additional Information

Fort Calhoun Station (FCS) provides the following responses:

Environmental RAI-01 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.

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.

Request:

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).

Attachment 1 Response to NRC Request for Additional Information

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.

FCS Response:

FCS has reviewed the changes in LTP Revision 2 against the scope of what was previously considered in the Environmental Assessment for the License Termination Plan at Fort Calhoun (ML23333A049). FCS concludes that any potential environmental impacts from the proposed changes in LTP Revision 2 do not go beyond the scope of the Environmental Assessment. Although the DCGLs were increased when using grout, this did not increase the dose contribution to groundwater and an Average Member of the Critical Group (AMCG). Additionally, the residual radioactivity in the basements will be reduced to levels that are ALARA without factoring in the reduction in releases due to grouting. Section 6.13 of LTP Chapter 6, Revision 2, details the dose modeling for the revised DCGLs. The model considers all reasonable dose pathways to the AMCG, which includes groundwater. Whether deep soil, groundwater, or other media is considered, the license termination rule is based on total effective dose equivalent to an AMCG (10 CFR 20.1402) and not on the quantity of radioactivity left behind.

The following conclusion was reached in LTP Chapter 8, Revision 2:

The potential environmental impacts associated with decommissioning FCS have already been predicted in and will be bounded by the previously issued environmental impact statements (PSDAR, NUREG-0586, and FCS Environmental Statement). Therefore, there are no new or significant environmental changes associated with decommissioning.

This conclusion remains true considering the LTP Revision 2 changes. However, Chapter 8 has been updated to address an additional NRC request to include explicit discussion on the proposed action, purpose of the proposed action, and alternative actions in light of the LTP Revision 2 changes.

34 Pages Follow Proposed License Termination Plan (Marked-Up Chapter 8, Revision 2)

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN CHAPTER 8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT REVISION 2

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-i TABLE OF CONTENTS 8

SUPPLEMENT TO THE ENVIRONMENTAL REPORT............................................ 8-1 8.1 Introduction................................................................................................................... 8-1 8.1.1 Purpose...................................................................................................................... 8-1 8.1.2 Background................................................................................................................ 8-1 8.1.3 Proposed Action........................................................................................................ 8-2 8.1.3.1 Purpose of and Need for the Proposed Action............................................... 8-2 8.1.3.2 Alternative to the Proposed Action................................................................ 8-2 8.2 Site Location and Description....................................................................................... 8-2 8.2.1 Site Description after Unrestricted Release............................................................... 8-3 8.3 Remaining Dismantlement and Decommissioning Activities...................................... 8-5 8.4 Impacts to the PSDAR.................................................................................................. 8-5 8.5 Fort Calhoun Station Environmental Description......................................................... 8-6 8.5.1 Geography and Demography..................................................................................... 8-6 8.5.1.1 Site Location and Description........................................................................ 8-6 8.5.1.2 Population....................................................................................................... 8-6 8.5.1.3 Site Access, Land, and Water Use.................................................................. 8-7 8.5.1.4 Climate............................................................................................................ 8-7 8.5.2 Geology and Seismology........................................................................................... 8-8 8.5.3 Hydrology and Hydrogeology................................................................................... 8-8 8.6 Environmental Effects of Decommissioning................................................................ 8-9 8.6.1 Summary.................................................................................................................... 8-9 8.6.2 Radiological Effects of Decommissioning.............................................................. 8-10 8.6.2.1 Occupational Radiation Exposure................................................................ 8-10 8.6.2.2 Off-Site Radiation Exposure and Monitoring.............................................. 8-11 8.6.2.3 Environmental Effects of Accidents and Decommissioning Events............ 8-12 8.6.2.4 Storage and Disposal of Low-Level Radioactive Waste.............................. 8-12 8.6.2.5 Radiological Criteria for License Termination............................................. 8-13 8.6.3 Non-radiological Effects of Decommissioning....................................................... 8-13 8.6.3.1 On-Site Land Use......................................................................................... 8-13 8.6.3.2 Off-Site Land Use (in the Vicinity).............................................................. 8-14 8.6.3.3 Water Use..................................................................................................... 8-15 8.6.3.4 Water Quality............................................................................................... 8-15 8.6.3.5 Air Quality.................................................................................................... 8-16 8.6.3.5.1 Worker Transportation.............................................................................. 8-16 8.6.3.5.2 Dismantling Systems and Removal of Equipment.................................... 8-16 8.6.3.5.3 Movement and Open Storage of Materials On-Site.................................. 8-17 8.6.3.5.4 Demolition of Buildings or Structures...................................................... 8-17 8.6.3.5.5 Shipments of Material to an Off-Site Location......................................... 8-17

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-ii 8.6.3.6 Aquatic Ecology........................................................................................... 8-18 8.6.3.7 Terrestrial Ecology....................................................................................... 8-18 8.6.3.8 Threatened or Endangered Species............................................................... 8-19 8.6.3.9 Occupational Issues/Safety........................................................................... 8-21 8.6.3.10 Cost............................................................................................................... 8-22 8.6.3.11 Socioeconomic Impacts................................................................................ 8-22 8.6.3.12 Environmental Justice................................................................................... 8-22 8.6.3.13 Cultural, Historic, and Archaeological Resources........................................ 8-23 8.6.3.14 Aesthetics...................................................................................................... 8-24 8.6.3.15 Noise............................................................................................................. 8-24 8.6.3.16 Irretrievable Resources................................................................................. 8-24 8.6.3.17 Traffic and Transportation............................................................................ 8-25 8.6.3.18 Placement of Clean Concrete Demolition Debris and Sand Mix in Major Building Basements: Terrestrial Ecology and Transportation........................................ 8-25 8.7 Overview of Regulatory Governing Decommissioning Activities and Site Release.. 8-25 8.7.1 Federal Requirements.............................................................................................. 8-25 8.7.1.1 NRC.............................................................................................................. 8-26 8.7.1.2 EPA............................................................................................................... 8-26 8.7.2 State and Local Requirements................................................................................. 8-26 8.8 Conclusion................................................................................................................... 8-27 8.9 References................................................................................................................... 8-28 LIST OF TABLES Table 8-1 Summary of the Environmental Impacts from Decommissioning...................... 8-29

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-iii ABBREVIATIONS AEC Atomic Energy Commission ALARA as low as is reasonably achievable AMSL above mean sea level BMP best management practices CE Combustion Engineering CNW Chicago and Northwestern DCGL derived concentration guideline level DSAR Defueled Safety Analysis Report FCS Fort Calhoun Station FSS final status survey GEIS general environmental impact statement GTCC greater than Class C HASP health and safety plan IOF ISFSI Operations Facility ISFSI Independent Spent Fuel Storage Installation LTP license termination plan LLRW low-level radioactive waste MW megawatts NDEQ Nebraska Department of Environment Quality NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NSHPO Nebraska State Historic Preservation Office OCA Owner Controlled Area ODCM Off-Site Dose Calculation Manual OPPD Omaha Public Power District PCB polychlorinated biphenyls PSDAR Post Shutdown Decommissioning Activity Report PWR pressurized water reactor REMP Radiological Environmental Monitoring Program

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-iv RGPP Radiological Groundwater Protection Program RP radiation protection SEIS supplemental environmental impact statement SWPPP Storm Water Pollution Prevention Plan EPA U.S. Environmental Protection Agency

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-1 8

SUPPLEMENT TO THE ENVIRONMENTAL REPORT 8.1 Introduction In accordance with the requirements of 10 CFR 50.82(a)(9)(ii)(G) and the guidance of Regulatory Guide 1.179, Standard Format and Contents for License Termination Plans for Nuclear Power Reactors [1], this chapter provides a supplement to the environmental report describing any new information or significant environmental change associated with the site-specific decommissioning and site closure activities performed at the Fort Calhoun Station (FCS) site.

8.1.1 Purpose This chapter supplements the Omaha Public Power District (OPPD) Updated Environmental Report - Fort Calhoun Station as supplemented [2], describing any new information or significant environmental changes associated with the site-specific decommissioning and license termination activities presented in this License Termination Plan (LTP). The supplement includes a detailed description of the remaining decommissioning and site closure activities, the interaction between those activities and the environment, and the likely environmental impact of those activities. The supplement discusses whether the activities and their impacts are bounded by the impacts predicted by the U.S. Atomic Energy Commission (AEC) Final Environmental Statement related to operation of Fort Calhoun Station Unit 1 (AEC Environmental Statement)

[3]; NUREG-1437, Supplement 12, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Regarding Fort Calhoun Station, Unit 1 [4]; and the FCS Post Shutdown Decommissioning Activity Report (PSDAR) [5]. This chapter discusses decommissioning activities, with a focus on those activities to be performed from time of submittal of this LTP until the licensees completion of decommissioning activities.

8.1.2

Background

FCS is comprised of one 533.7 MWe pressurized water reactor (PWR) unit, with supporting facilities, which was operated by OPPD from 1973 to 2016.

The station was granted a construction permit by the AEC in 1968, and first commercial operation was achieved in 1973. OPPD made the decision to permanently shut down FCS due to a variety of factors, including economic analyses associated with production cost, economies of scale issues, and excess system supply. Permanent cessation of operations at FCS occurred on October 24, 2016. Certification of Permanent Defueled Status was achieved on November 13, 2016.

In accordance with the requirements of 10 CFR 50.82, OPPD submitted the initial revision of the PSDAR to the U.S. Nuclear Regulatory Commission (NRC) on March 30, 2017. The reactor at FCS remained in a SAFSTOR condition until December 16, 2019. At this point, the PSDAR was amended to address the acceleration of decommissioning activities, change the decommissioning schedule and cost milestones, and commit to notifying the NRC of the final disposition of the reactor closure vessel head. The amended PSDAR established the DECON method as the current decommissioning approach and described the accelerated decommissioning schedule with a lower revised cost estimate to reflect current knowledge and waste disposal options.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-2 The environmental impacts of decommissioning operations at FCS were assessed as part of the PSDAR submittal. The assessments included the evaluation of impacts against those noted in the AEC Environment Statement and NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (GEIS) [6]. The reference facility used from NUREG-0586 is an approximately 931 MWe PWR, operated by Maine Yankee Atomic Power Company and designed by Combustion Engineering (CE). The FCS PWR, designed by CE, had a much lower power output. With the power output of FCS lower than that of the reference plant, the use of the reference site will provide a bounded comparison of the generic environmental assessment.

The amended PSDAR concluded that the decommissioning of the FCS would be accomplished with no significant adverse environmental impacts and that the environmental impacts associated with the site-specific decommissioning activities for FCS would be bounded by previously-issued environmental impact statements.

8.1.3 Proposed Action The proposed action is the review and subsequent approval of the FCS LTP. This action was complete with the approval of Revision 1 of the FCS LTP; however, the action is revived to address the License Amendment Request for Revision 2 of the FCS LTP. LTP Revision 2 incorporates revised dose calculations for the Auxiliary Building basement, requirements for remediation, and survey methodologies.

8.1.3.1 Purpose of and Need for the Proposed Action The purpose of and need for the proposed action is to allow for completion of decommissioning of the FCS site, termination of the FCS operating license, and subsequent release of the FCS site for unrestricted use. The approval of the LTP ensures that final decommissioning activities are appropriately completed.

The FCS site intends to meet the criteria for unrestricted use. Chapters 5 and 6 of this LTP detail the final status survey (FSS) process and derived concentration guideline levels (DCGLs) used to demonstrate compliance with 10 CFR 20.1402. The site intends to use grout as fill material to eliminate groundwater in-leakage from foundation fractures and to mitigate dose. As such, LTP Revision 2 includes significant changes within Chapters 5 and 6 to several DCGLs and introduces grout DCGLs.

8.1.3.2 Alternative to the Proposed Action There is no alternative to the proposed action that would allow approval of the FCS LTP and subsequent release of the site for unrestricted use after demonstrating compliance with the release criteria specified in 10 CFR 20.1402.

8.2 Site Location and Description The FCS site is located on the southwest bank of the Missouri River at river mile 646.0, approximately 19.4 miles north of Omaha, Nebraska. LTP Chapter 1, Figure 1-1, shows the geographical location of the site relative to nearby towns, cities, and the river. OPPD has a

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-3 perpetual easement on approximately 117 acres of land primarily on the northeast bank of the river directly opposite the plant buildings.

FCS is situated within parts of Sections 16, 17, 20, and 21, Township 18 North, Range 12 East of Washington County, Nebraska in the Modale, IA quadrangle. The site is part of the Missouri River bottomland, which is a nearly level plain about 15 miles wide at Blair, Nebraska, 8 miles wide at the site, and narrowing to 3 miles wide in the vicinity of Omaha-Council Bluffs. On the southwestern part of the site, the ground rises sharply about 60 feet to a higher-level area, which is bounded on the south by U.S. Highway 75, formerly U.S. Highway 73.

The elevation of this plain averages about 1,000 feet above mean sea level (AMSL) at the site.

The surface of the land, starting from the Missouri River at about 997 feet AMSL, falls to an old channel of the river before rising again to approximately 1,004 feet AMSL. Beyond this point, the land then gradually falls off to about 1,000 feet AMSL, rises again to approximately 1,020 feet AMSL, and then rises approximately 60 feet to a higher plateau at elevation 1,080 feet AMSL. LTP Chapter 1, Figure 1-4, provides a depiction of the FCS site topography.

The site is comprised of approximately 660 acres, which is owned or controlled by OPPD. A portion of the property has been previously removed from the FCS License but is maintained under OPPD ownership. LTP Chapter 1, Figure 1-2, provides a depiction of the FCS Owner Controlled Area (OCA).

A rail spur from the Chicago and Northwestern (CNW) Railway was constructed to serve the construction of the FCS. The original CNW tracks and rail spur have since been removed. In 1994, a permanent easement was granted to allow the construction of a new rail spur in the approximate location of the old CNW railway to allow trains to serve the Cargill industrial facility located north of FCS. In late 2020, OPPD added three lines (Lines A, B, and C, approximately 1,360, 1,595, and 2,230 feet in length, respectively) to the rail spur to allow for the direct loading of waste into rail cars. The added rail lines will remain in place after license termination with the exception of the portion of the line that resides within the waste processing structure.

8.2.1 Site Description after Unrestricted Release This section provides a summary of the final condition of the site at the conclusion of decommissioning and site closure activities. The End State is defined as the configuration of the remaining below-ground basements, above-ground structures, piping, and open land areas at the time of license termination. Chapters 3 and 6 of the LTP provide more detailed discussions of the FCS end state.

The following above-ground buildings will remain at the time of license termination: Training Center, FLEX Building, OCA Entrance Building, 3451 Old Building, 3451 New Building, and the 1251 Control and Switchgear Building. With the exception of the removal of the 345kv and 161kv lines to the station, the Switchyard will remain after decommissioning. All other structures will be removed to a minimum of three feet below grade (approximately 1,001 feet AMSL). Because there are no dose model implications, if the number and identification of above-ground buildings to remain and be subject to final status survey (FSS) changes, the NRC will be notified.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-4 For the Containment Building basement, all concrete will be removed from the inside of the steel liner, leaving only the remaining exposed liner below 1,001 feet AMSL and the structural concrete outside of the liner. In the Auxiliary Building basement, all internal walls and floors below 1,001 feet AMSL will be removed, leaving only the reinforced concrete floors and outer walls of the building structures. In the Turbine Building, all interior walls and floors below 1,001 feet AMSL will be removed with the exception of the turbine pedestals. For the Spent Fuel Pool, the only portion of the structure that will remain is the lower pool below the 1,001 feet AMSL and the concrete structure of the Fuel Transfer Canal after the steel liner has been removed.

There are additional below-ground structures that will remain, including the lower concrete portions of the Circulating Water inlet piping and Circulating Water discharge tunnels.

An evaluation was performed regarding the disposition of the Intake Structure. The option to leave the structures basement in place below 1,001 feet AMSL and backfill was determined to be the least disruptive to the environment. The impact of leaving the Intake Structure and intake and discharge piping in place is discussed in a correspondence developed by Olsson Engineering with the Army Corps of Engineers [7].

For all excavations created by the removal of buried piping, components, or slab-on-grade structures, a radiological assessment will be performed prior to backfill. For all below-ground basements that will remain, an FSS will be performed, and contingent upon the completion of confirmatory surveys and regulatory approval, the basements will be backfilled. If a major below-ground building has been removed in its entirety, an FSS will be performed on the resultant excavation (using the most-restrictive classification of the building prior to demolition) prior to backfill of the excavation. All void spaces will be backfilled using clean fill material to grade (1,004 feet AMSL). An exception to this would be the use of grout to fill the trenches of the Auxiliary Building 989 feet elevation and the Stressing Gallery. The end state will also include a range of buried piping, embedded piping, and penetrations. All buried piping that is abandoned in place will be capped and/or filled with grout. The restored areas on the site will be backfilled, graded, and returned to natural contours. The demolition debris will be segregated for recycling or disposal.

The ISFSI, ISFSI Operations Facility (IOF), and support structures will remain in the reduced 10 CFR Part 50 license and are not within the scope of the proposed partial site release.

Several structures will remain at the end state as requested by OPPD. These structures are as follows:

• OPPD Electrical Switchyard and supporting structures (note: the Switchyard will remain in active use after decommissioning in support of the existing OPPD off-site electrical transmission and distribution system)

• FLEX Building

• Training Center

• Training Center - Sanitary Sewage System

• OCA Entrance Building

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-5

• Paved roadways and rail lines, including the lines and rail spur constructed in 2011 and 2020, allowing for rail service at the site via connection to the nearby Union Pacific railway After all demolition and remediation activities are compete, OPPD will use the FSS process described in Chapter 5 of this LTP to demonstrate that the FCS and surrounding open land areas, with the exception of the ISFSI, comply with radiological criteria for unrestricted use specified in 10 CFR 20.1402. As part of the decommissioning process, all reactor fuel was loaded into casks and transferred to the ISFSI. The greater than Class C (GTCC) waste will be segregated and transported for storage in the ISFSI. It is expected that the fuel will remain on-site in dry storage within the ISFSI until it is transferred as determined by the U.S. Department of Energy.

The ISFSI, which occupies approximately 6.5 acres, was constructed in the northwest corner of the previous FCS protected area, northeast of the OPPD switchyard.

Following the conclusion of radiological remediation activities and prior to initiating final survey, isolation and control measures will be implemented. The control measures will be implemented to ensure the final radiological condition is not compromised by the potential for recontamination as a result of access by personnel or equipment. Open land areas, access roads, and boundaries will be posted with signs restricting access. Isolation and control measures will be implemented through approved plant procedures and will remain in force throughout FSS activities, until there is no risk of recontamination from decommissioning or the survey area has been released from the license.

Several services, such as the Blair City water service and OPPD electrical service, will remain in operation to support the ISFSI monitoring and security operations. The station monitoring wells will remain in service for continued periodic sampling. There are no potable wells in service on site. Water service is provided through the City of Blair municipal water supply which draws water from the Missouri River via a water intake about 5 miles north of the site.

The Missouri River, which flows generally north to south, forms the northeast to southeast site boundary. This part of the river is referred to by the Army Corps of Engineers as the Blair Bend.

The river limits are under control of the Army Corps of Engineers who have established a structure azimuth line, which acts as another site boundary.

8.3 Remaining Dismantlement and Decommissioning Activities Key dismantlement and decommissioning activities that have been completed include activities associated with the removal of system piping and components, the segmentation and packaging of the internals from the FCS reactor, and the demolition and disposal of several ancillary structures.

Chapter 3 of this LTP provides details on the dismantlement, demolition, and remediation activities currently performed and remaining activities to be executed to achieve the end state condition.

8.4 Impacts to the PSDAR The PSDAR, amended in December 2019, describes the planned decommissioning operations at the site and concludes that the potential environmental impacts associated with decommissioning

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-6 the site have already been postulated in, and will be bounded by, the previously issued environmental impact statements, specifically:

• Final Environmental Statement, as amended and supplemented

• NUREG-0586

• NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities [8]

Chapter 3 of this LTP identified the dismantlement and decontamination activities that are scheduled to be completed prior to unrestricted release of the site (excluding the ISFSI footprint).

These identified activities are not significantly different from what was proposed in the PSDAR.

Although additional details regarding major decommissioning activities will be defined during ongoing decommissioning planning efforts, no significant impacts beyond those identified in the PSDAR have been identified. Subsequent sections in this chapter provide additional evaluation and information regarding the environmental effects of decommissioning.

8.5 Fort Calhoun Station Environmental Description 8.5.1 Geography and Demography 8.5.1.1 Site Location and Description The site location and description were previously discussed in Section 8.2. FCS is situated within parts of Sections 16, 17, 20, and 21, Township 18 North, Range 12 East of Washington County, Nebraska in the Modale. IA quadrangle. The site is part of the Missouri River bottomland, which is a nearly level plain about 15 miles wide at Blair, Nebraska, 8 miles wide at the site, and narrowing to 3 miles wide in the vicinity of Omaha-Council Bluffs. The elevation of this flood plain averages about 1,000 feet AMSL at the site. On the southwestern part of the site, the ground rises sharply about 60 feet to a higher, level area, which is bounded on the south by U.S.

Highway 75, formerly U.S. Highway 73. The topography at the site ranges from approximately 997 feet to 1,080 feet AMSL and represents a river bottom deposit along the Missouri River subsequent to the most recent period of glaciations.

8.5.1.2 Population According to the U.S. Census Bureau American Community Survey report from 2010 [9], the population of Washington County is 20,234. The nearest municipality is the city of Blair, Nebraska, about three miles northwest, with a population of 7,990. Fort Calhoun, Nebraska, is about five miles southeast with a population of 908. Kennard Village, Nebraska, about seven miles from the plant site has a population of 167. Omaha, Nebraska, and Council Bluffs, Iowa, metropolitan area is 10 to 25 miles southeast of the site with a majority of the population beyond the 15-mile radius from the site with a population of 789,342. Missouri Valley, Iowa, about 11 miles east, has a population of 2,838.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-7 8.5.1.3 Site Access, Land, and Water Use The remaining site encompasses approximately 540 acres and is located on the alluvial plain of the Missouri River in a predominantly agricultural region roughly ten miles north of the Omaha metropolitan area. The site is relatively isolated and is bordered to the northwest by an industrial facility and farm fields, to the southeast by farm fields, to the south by a state highway with scattered residence, and to the north by the Missouri River, farm fields, and a wild life refuge area. The Missouri River is also used for commercial barge and recreational boat traffic.

According to the Historical Site Assessment for Fort Calhoun Station [10], there are no residences within 0.5 miles of FCS, as measured from the center of the Auxiliary Building stack.

The seven nearest residences are from 3,000 to 4,000 feet distant. There are no schools, hospitals, prisons, motels, or hotels in the immediate vicinity of the site.

8.5.1.4 Climate Nebraska is located midway between two distinctive climate zones, the humid east and the dry west. Cyclic weather conditions representative of either zone, or combinations of both, occur.

Changes in weather result from the invasion of large masses of air with dissimilar properties.

These air masses tend to get their characteristics from either the warm and humid south-southeast, the warm and dry southwest, the cool and dry north-northwest, or the cold continental polar air of the north. The region is also affected by many storms or cyclones (areas of low pressure) which travel across the country, generally from west to east. Periodic and rapid changes in the weather are normal, especially in the winter. The mean annual temperature for the region is 51.1 degrees Fahrenheit. The January monthly mean is 20.2 degrees Fahrenheit, while that for July is 77.7 degrees Fahrenheit.

Annual average precipitation for the region is about 28.5 inches, but annual amounts vary widely from year to year. About 75 percent of the precipitation occurs during showers and thunderstorms from April through September. Snowfall amounts to about 30 inches of snow as the annual average, but total annual amounts vary widely from year to year.

The surface wind direction and speed are quite varied during all seasons of the year. The prevailing wind direction from May through December is from south-southeast; north-northwesterly winds prevail during the remainder of the year. The mean annual wind speed is 10.6 miles per hour.

Tornado events in the counties surrounding FCS since 1950 include: Washington County, NE, recorded 19 events, Douglas County, NE, recorded 20 events, Pottawattamie County, IA, recorded 42 events, and Harrison County, IA, recorded 23 events. On June 7, 1953, a category F2 tornado, 5.7 miles away from the FCS, injured one person and caused an estimated $25,000 in damages. On May 6, 1975, a category F4 tornado, 16.9 miles away from FCS, killed three people, injured 133 people, and caused approximately $250,000,000 in damages. There has been no reported tornado causing damage within five miles of the Station (Source: National Centers for Environmental Information, NOAA website [11]).

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-8 8.5.2 Geology and Seismology The soils below FCS include thick beds of limestone, dolomite, shale, sandstone, and thin layers of coal beds. The deeper formations were deposited in marine depositional environments with the shallow soils from the lateral migration of the paleo river channel. The major tectonic features of the mid-continent region began to develop late in the Paleozoic Era, and probably most of the important structural features of the Nebraska-Iowa Missouri River Valley area had already developed or were developing by the end of Permian period. However, there is no record of movement of the fault in historic times, or any indication of activity in recent geologic time.

At the beginning of the Pleistocene period, the Missouri River Valley and its main tributaries were established in their approximate present positions. Subsequently, under successive glacial movements, the valleys were filled and re-opened several times. During this period, the Peorian loess was deposited on the terraces and adjacent uplands. It is probable that only the upper part of the alluvium in the Missouri River Valley is actually of recent age and that deeper deposits are mostly of Pleistocene age.

According to the Defueled Safety Analysis Report (DSAR), unconsolidated sediments at the plant site generally range from 65 to 75 feet in thickness. The soils are typically interstratified and cross-bedded. These soils may be grouped generally into two units:

• an upper fine-grained sandy clay with silt approximately 20 to 50 feet thick

• an underlying carbonate bedrock surface at a depth of approximately 65 to 75 feet below ground surface The upper units were representing former river deposits and are not likely continuous, but rather have preferential channels formed by paleo-oxbow deposits.

Pennsylvanian-aged limestone and shale (bedrock) of the Kansas City Formation are encountered below the overburden soils. The bedrock below the site consists of various types of limestone formations.

The site lies in a region of infrequent seismic activity. Since the middle of the 19th century, from the first historical record of earthquake occurrence in the area, only 13 shocks with epicentral Modified Mercalli Intensities of V or greater have occurred within 200 miles of the plant site.

Only one earthquake of Modified Mercalli Intensity VI has been reported within 200 miles of the site. It occurred in March 1935, near Tecumseh, Nebraska.

8.5.3 Hydrology and Hydrogeology Water levels recorded at the site show that the groundwater gradients are nearly flat, with only a gentle slope toward the river, about 10 feet below the ground surface. Water levels at the site varied from elevations 993.7 to 992.4 feet, while the river levels recorded during this same period ranged from elevations 993.2 to 992.4 feet. Groundwater levels vary with changes in the river level. The rate of groundwater flow in the alluvial soils varies with the permeability; however, the groundwater flow rate, or velocity, is very slow due to the low gradients. The coefficient of permeability varied from about 0.5 to 3 feet per day in the upper sandy silt and

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-9 silty sand. In the lower fine-to-coarse sands and gravels, coefficients of permeability as high as 20 feet per day were measured.

According to the DSAR, groundwater flow directions have been reported to be both toward the Missouri River (northeasterly) and away from the Missouri River (south-southwesterly). Flow directions towards the river appear to represent times when Missouri River levels are relatively low (e.g., during the spring, summer, and early fall, when most precipitation occurs and the river flow is relatively high). Flow directions away from the river appear to represent times when Missouri River levels are relatively high, causing bank storage effects (e.g., during late fall and winter when the river recedes).

The FCS site is bounded on the northeast and southeast by a portion of the Blair Bend of the Missouri River. The Corps of Engineers maintains river structures to prevent further meandering of the channel within the alluvial flood plain; the structures take the form of pile dikes and revetments.

Fish Creek is an intermittent drainage stream that runs along the northwest boundary of the ISFSI Protected Area, which is on the northwest boundary of the deconstruction area. This stream discharges into a larger wetland, before flowing in the Missouri River.

8.6 Environmental Effects of Decommissioning 8.6.1 Summary The evaluation and methodology of the environmental effects (or impacts) of the decommissioning of FCS follows the approach outlined in the GEIS. This approach includes identification of environmental issues as either generic or site-specific. If the issue is considered generic, it is assigned a significance level of either Small, Moderate, or Large. If identified as generic, the environmental impact is considered to be bounded by the evaluation in the GEIS, which concludes that the impact significance is Small. In this event, site-specific evaluation by licensees is generally not required.

For those environmental issues or decommissioning activities that require site-specific evaluation, a standard approach is followed. It is summarized as follows:

1)

The issue or activity is summarized including a summary of the impacts as reported in the original Environmental Statement (ES) and PSDAR. Note that many decommissioning activities are not identified in these documents.

2)

Applicable regulations, permits, limits or other regulatory requirements are identified.

3)

Potential impacts from decommissioning activities relating to the environmental issue are described.

4)

An evaluation is performed. This includes analysis and professional judgment to estimate or determine whether the activity is likely to make a noticeable impact on the environment considering the available information. If an impact is likely, existing and additional mitigation measures that can be taken are evaluated. If an impact cannot be avoided, a determination is made as to whether the impact is likely to seriously damage the resource or attribute.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-10

5)

A conclusion is reached. A conclusion is derived from the evaluation steps summarized above. The conclusion identifies the level of significance of the impacts. Site-specific issues are not bounded by the GEIS evaluation.

Table 8-1 was used as the basis for the site-specific environmental impact assessment for FCS. It is excerpted from Table 6.1 of NUREG-0586, Supplement 1. The first step in this process is to screen the issues to identify those that are site-specific. Decommissioning activities specific to FCS are then reviewed, and the activities that may require site-specific evaluation are identified.

The screening identified the following:

• off-site land use activities: changes in demographics and zoning that have occurred in the past 40 years

• aquatic ecology affected by activities beyond the operational area: changes in designation of sensitive areas (local wetlands and Missouri River bank)

• terrestrial ecology affected by activities beyond the operational area: changes in designation of sensitive areas (local wetlands and Missouri River bank)

• threatened and endangered species: changes in local flora and fauna and designation of threatened and endangered species that have occurred in the past 40 years

• environmental justice: changes in demographics and socioeconomic status in the past 40 years

• cultural and historic resource impacts beyond the operational areas: changes in local historic landmark designations and other cultural resources The following decommissioning activities, which required evaluation of impacts across several environmental attributes or issues, were identified:

• rail line upgrade and extension (on-site)

• Circulating Water inlet and outlet piping disposition impact on aquatic ecology (within and beyond the operational area) 8.6.2 Radiological Effects of Decommissioning 8.6.2.1 Occupational Radiation Exposure During decommissioning, OPPD has implemented, and will continue to implement, a Radiation Protection (RP) Program in accordance with the license specifications and the requirements of 10 CFR Part 20. The objectives of the RP Program are to control radiation hazards, avoid accidental radiation exposures, maintain occupational worker exposures to less than the administrative limit of less than 2,000 mrem/year total effective dose equivalent, and to maintain doses to workers and the public as low as is reasonably achievable (ALARA).

On October 24, 2016, OPPD placed FCS in a SAFSTOR condition (a period of safe storage of the stabilized and defueled facility). The reactor at FCS remained in a SAFSTOR condition until December of 2019, when FCS changed the decommissioning method to DECON. This period allowed for the decay of most short-lived radionuclides, which subsequently, reduced radiation

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-11 levels at the facility. This, combined with the effective implementation of the RP Program and ALARA measures, minimizes the projected and actual occupational radiation dose exposure during the decommissioning of FCS. It is anticipated that the most significant contributors to occupational dose from remaining dismantlement activities is the segmenting, packaging, and shipping of the reactor vessel internals and the reactor vessel.

The GEIS estimates that 560 to 1000 person-rem would be needed to decommission a PWR. The current occupational dose expended and dose expected to complete decommissioning for FCS is estimated to be approximately 285 person-rem. This is below the GEIS estimate.

As the occupational dose for the decommissioning will meet the regulatory standards of 10 CFR 20, it is therefore bounded by the criteria in the GEIS, and the impact is considered Small.

8.6.2.2 Off-Site Radiation Exposure and Monitoring OPPD implements a regulatory compliant Radiological Environmental Monitoring Program (REMP) at FCS, which provides annual reports with an accurate assessment of the radiological environment in and around the environs of the site. The REMP provides assurance that the radioactive gaseous and liquid effluent releases during plant operations do not exceed the concentration limits of 10 CFR 20, the dose limits of 10 CFR 50, Appendix I, or the fuel cycle dose limits of 40 CFR 190. OPPD and EnergySolutions will continue to adhere to these limits throughout the course of the decommissioning.

At FCS, the Circulating Water Discharge Tunnel is the main authorized effluent release pathway for the discharge of treated and filtered radioactive liquid waste to the Missouri River. Liquid effluents are monitored and sampled prior to release from on-site storage tanks.

The gaseous pathway analysis is subject to the meteorological conditions during the time of the release. Due to plant shutdown and cessation of noble gas and other radionuclide generation, gaseous effluents do not present a significant release or exposure pathway. Routine air sampling is performed to determine the dose due to radioactive gaseous releases.

The direct radiation exposure is measured continuously with the use of passive monitoring devices. The dose is integrated over three months to accumulate a statistically significant exposure.

The design basis for the ISFSI precludes airborne radioactive releases during spent fuel storage and provides adequate shielding to minimize exposure. Radiation monitoring for the ISFSI is performed in accordance with the RP Program implemented at FCS. In accordance with the worst-case scenario in the design basis, the projected doses at the site boundary are substantially below the limits established in 10 CFR 72.106(b) where there is total loss of the confinement barrier. Exposure from the ISFSI to the nearest permanent resident will not exceed 25 mrem/year as specified in 10 CFR 72.104 and 40 CFR Part 190.

Consequently, the public dose from decommissioning is bounded by the criteria in the GEIS, and the impact is considered Small.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-12 8.6.2.3 Environmental Effects of Accidents and Decommissioning Events Decommissioning accident analysis is integral to the licensing design basis for FCS. While decommissioning radioactively contaminated structures, systems, and components at FCS, it is necessary to assure the safety of the public in the surrounding area and workers. Worker safety is addressed in the RP and Safety programs for the FCS decommissioning project, which rely on ALARA principles and the FCS-SAF-103, FCS Deconstruction Health and Safety Plan (HASP) [12]. The safety of the public is principally related to potential hazards associated with an airborne release of radioactive materials during decommissioning operations.

During decommissioning, FCS will perform decontamination and dismantlement of structures, systems, and components in addition to maintenance, waste management, and surveillance. The accidents discussed in NUREG-0586, Supplement 1 associated with immediate dismantling would also be applicable during the decommissioning of FCS. However, the potential consequences associated with those accidents would be less at FCS because of the reduction of the total radionuclide inventory at FCS due to:

• decontamination efforts made before decommissioning,

• prior radioactive waste shipments, and

• radioactive decay.

Consequently, the potential decommissioning accidents at FCS are bounded by the accident evaluation presented in NUREG-0586, Supplement 1.

Operational accidents during decommissioning could result from equipment failure, human error, and service conditions. With the spent nuclear fuel located in the ISFSI, operational accidents during decommissioning can be categorized as follows:

• radioactive waste transportation accidents

• explosions and/or fires associated with explosive and/or combustible materials

• loss of contamination control

• natural phenomena

• human caused events external to FCS These potential operational accidents during decommissioning are addressed in NUREG-0586, Supplement 1 for immediate dismantlement and, consequently, are bounding for the decommissioning of FCS.

8.6.2.4 Storage and Disposal of Low-Level Radioactive Waste The decommissioning of FCS has required, and will continue to require, the disposal of large volumes of low-level radioactive waste (LLRW), including contaminated equipment, tools, clothing, and bulk debris materials such as concrete, metal, and asphalt. Materials that cannot be free released are, and will continue to be, dispositioned as LLRW. Through the proper implementation of the Waste Management Program, Process Control Program, and associated

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-13 procedures, OPPD ensures the appropriate segregation, classification, processing, packaging, shipment, and control of solid, liquid, and gaseous radioactive wastes.

The majority of the Class A LLRW from FCS will be shipped to the EnergySolutions disposal site in Clive, Utah. No significant impacts are expected from the disposal of LLRW. The total volume of LLRW for disposal was estimated in the Decommissioning Plan to be approximately 6,000,000 cubic feet. Actual waste volumes and classifications may vary. The vast majority of waste will be loaded into 8-120A or 3-60B casks, gondola rail cars, or articulating bulk cars and shipped to Clive, Utah. Oversized or overweight components, such as the reactor vessel head, are shipped using multiple axle tractor/trailer rigs or special rail cars. Rail and truck shipments are made in accordance with U.S. Department of Transportation regulations.

OPPD completed the construction of the ISFSI in 2005 with initial loading of 10 dry storage casks (DSC) commencing in August 2006 and completed in August 2009. The final spent nuclear fuel cask loading campaign started in October 2019 and concluded in May 2020. OPPD completed the transfer of all its spent nuclear fuel contained in 40 DSCs to the ISFSI, in May 2020. The multi-purpose fuel canisters within the casks are seal-welded and leak tight; therefore, no leakage is expected during normal operation, off-normal conditions, or design basis events. The storage of the fuel at the ISFSI does not generate any gaseous, liquid, or solid radioactive waste. The spent nuclear fuel will remain in storage at the ISFSI under the Part 50 license until the fuel is transferred to a permanent repository. GTCC waste will be stored in two seal-welded leak tight canisters within storage casks co-located at the ISFSI with the spent fuel.

8.6.2.5 Radiological Criteria for License Termination Following the completion of decontamination, dismantlement, and remediation activities, radiological surveys will be performed to demonstrate that the dose from any residual radioactivity remaining in as-left structure basements and soils at FCS (excluding the ISFSI) meets the unrestricted release criteria specified in 10 CFR 20.1402. Once the balance of the site is remediated and the as-left radiological conditions are demonstrated to be below the unrestricted release criteria, the 10 CFR Part 50 license will be reduced to the area around the ISFSI. LTP Chapter 5 and Chapter 6 provide the methodology for demonstrating compliance with the unrestricted release criteria.

8.6.3 Non-radiological Effects of Decommissioning 8.6.3.1 On-Site Land Use The environmental impact associated with on-site land uses have been determined by the NRC within Section 4.3.1 of NUREG-0586, Supplement 1 to be generically considered as a Small impact.

The decommissioning project is located and executed within the remaining boundary of the FCS property previously used for power generation. Some on-site roads have been refurbished, and a reinforced heavy haul path was constructed to support the transfer of radioactive waste to the rail tent. No barge slips are being utilized. The rail was originally installed during the construction of the station and was modified to support decommissioning activities. On-site land activities such as vehicle parking and equipment/container laydown, storage, staging, and waste loading occur,

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-14 and continue to occur, in a manner similar to when the facility was operational. Several structures such as the Switchyard, ISFSI, IOF, FLEX Building, Training Center, as well as all roadways and a majority of rail lines, will remain at license termination.

Uncontaminated concrete and other demolition debris, where radiological surveys demonstrate that the concrete is free of plant-derived radionuclides above background will be disposed of as clean waste. Demolition debris found to be contaminated or potentially contaminated based on process knowledge will be disposed of as LLRW. Consequently, the burial of demolition debris contaminated with residual radioactivity will not have the potential to affect land use and ground or surface water quality.

As during the operation of the facility, decommissioning activities have not been conducted in wetlands. The wetlands around the plant have been protected in accordance with environmental regulations and permits.

There is no information pertaining to any significant environmental changes associated with the site-specific decommissioning activities. Site closure will comply with applicable U.S.

Environmental Protection Agency (EPA) regulatory requirements.

In accordance with the guidance presented in the GEIS, the potential impacts to land use onsite are considered Small.

8.6.3.2 Off-Site Land Use (in the Vicinity)

Only areas within the existing site boundary will be used to support decommissioning and license termination activities (such as temporary storage and staging areas). Appropriate isolation and control measures will be instituted to prevent the spread of contamination. These measures will also be monitored to ensure their effectiveness. Thus, no environmental impacts associated with the use of off-site lands are anticipated from the decommissioning activities at FCS.

Of the 660-acre site, approximately 119 acres is designated as part of the area to be decommissioned. The remaining land belonging to OPPD contains structures, is part of the open area, or has already been released.

It is assumed that construction activities will disturb one acre or greater of soil and requires a National Pollution Discharge Elimination System (NPDES) Construction Storm Water General Permit from the Nebraska Department of Environment Quality (NDEQ) and possible NRC notification, prior to proceeding with the activity. OPPD has a Storm Water Pollution Prevention Plan (SWPPP) for decommissioning and construction activities at the FCS site. The SWPPP contains best management practices (BMPs) to avoid and/or minimize sediment and erosion discharges to watercourses and wetlands. All BMPs will be in place prior to initiating decommissioning/construction activities.

Once decommissioning is complete, decommissioned areas at FCS will be either be left as a gravel/paved area with appropriate permanent storm water controls left in place or restored back to grassland; therefore, there will be a net gain in undisturbed area at FCS and no significant adverse impacts to land use as a result of decommissioning.

Decommissioning activities are not being performed in areas defined as environmentally sensitive within the site boundary, nor in land which adjoins similar off-site land areas.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-15 Consequently, the off-site land areas are not affected by the decommissioning activities and the potential impacts to land use off-site are considered Small.

8.6.3.3 Water Use In accordance with Section 4.3.2 of NUREG-0586, Supplement 1, the environmental impact associated with water use has been determined to be generally applicable with a Small impact.

FCS is located on the bank of the Missouri River, and the Intake Structure affects approximately 80 feet of riverbank. The predominant water usage during the operation of FCS was the use of water from the Missouri River as secondary cooling water for the reactor systems. With the plant shutdown and fuel removed from the reactor and located in the ISFSI, the remaining use of the river is for dilution of released liquid waste. The use of water from the Missouri River during decommissioning activities is significantly less than the usage during operations.

Water from the Missouri river is used extensively for municipal and domestic water supplies.

There are multiple potable water intakes located on the Missouri river near FCS. The nearest substantial upstream intake is located about 1 mile northwest of the FCS site and downstream intake approximately 20 miles from the site. The City of Blair provides potable water services to support FCS. Potable water use during decommissioning operations is not expected to be greater than the potable water use experience during operations. The IOF sewage system is self-contained and does not release to the environment at the site. The Training Center will utilize a new on-site sewage waste system. Released wastewater will continue to be processed in accordance with the sites NPDES permits.

Consequently, in accordance with the GEIS, the potential impacts to water use are considered Small.

8.6.3.4 Water Quality The environmental impact evaluation associated with surface and groundwater quality in section 4.3.3 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

This section evaluates potential project effects on those portions of the natural environment related to surface water and groundwater. Surface water generally refers to streams, rivers, ponds, reservoirs, and lakes. At FCS, the nearby bodies of water are the Missouri River, surface streams near the site, including Fish Creek (immediately northwest of the IOF), Long Creek (0.7 miles southeast), DeSoto Lake (1.8 miles east), and the surrounding wetlands.

At FCS, all non-radiological water discharges to Fish Creek and the Missouri River are controlled under NPDES permits, including Storm water Discharges from Industrial Activity, Industrial, and General NPDES Permit Authorizing Dewatering Discharges Activity. These permits were issued by the NDEQ. In addition, impacts are greatly reduced through implementation of appropriate BMP for soil erosion and sedimentation control. There is no impact to the nearby lake.

Radiological impacts are minimized through adherence to Off-Site Dose Calculation Manual (ODCM) [13] limits and assessed through the REMP and the Radiological Groundwater

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-16 Protection Program (RGPP). Potential groundwater impacts are monitored by the routine sampling of 23 permanent on-site RGPP wells and other ground water locations at FCS.

As the water from the Missouri River is no longer used to cool operating reactor systems at FCS, the thermal impact to the Missouri River has been reduced.

No adverse impacts on surface water and groundwater are expected from the implementation of decommissioning activities. Consequently, the potential impacts to surface and groundwater quality are bounded by the GEIS and considered Small.

8.6.3.5 Air Quality The environmental impact evaluation associated with air quality in section 4.3.4 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

There are five non-radiological types of decommissioning activities listed in Section 4.3.4.3 of the GEIS that have the potential to affect air quality:

• worker transportation to and from the site

• dismantling of systems and removal of equipment

• movement of open storage of materials on-site

• demolition of buildings and structures

• shipment of material and debris to off-site locations 8.6.3.5.1 Worker Transportation The work force at FCS has decreased significantly from the time the plant ceased operation in 2016 to a work force of approximately 300 people. The work force will temporarily increase during decommissioning by approximately 150 people. There will also be occasional increases during specific D&D activities until completion. The work force during decommissioning will be smaller than the work force needed during plant construction and routine refueling/maintenance operations. Therefore, there will be no significant adverse changes in air quality associated with changes in worker transportation since these changes in worker transportation will generally not be detectable or destabilizing.

8.6.3.5.2 Dismantling Systems and Removal of Equipment There are potential sources of particulate matter that could impact air quality during the dismantlement of systems and the associated release of gases from systems during removal.

Several mitigation efforts can be used to minimize fugitive dust such as wet suppression and chemical stabilization agents. In addition, airborne contamination can be minimized by isolating certain contaminated areas and implementing the use of air filtration systems when activities are located in areas that are not ventilated to the plant stack and are likely to generate airborne radioactivity or other hazardous pollutants. Other sources of air pollutants such as refrigerants will be disposed of according to applicable local, state, and federal regulations. FCS complies with all applicable federal and state air quality regulations, including the requirements of the

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-17 NDEQ, and will implement the BMPs to minimize particulate matter generated during decommissioning and the released to the environment detectable off-site.

8.6.3.5.3 Movement and Open Storage of Materials On-Site Movement of equipment and open storage of materials such as construction debris and soil stockpiling during decommissioning may result in fugitive dust. However, BMPs such as temporarily stabilizing stockpiled soil with seed and mulch and spraying of the debris containing particulates and dust will minimize fugitive dust during stockpiling. Similar BMPs will be established to mitigate effects while moving material within the site. Therefore, no significant adverse impacts to air quality from the particulate matter generated as a result of movement or storage of material onsite are anticipated.

8.6.3.5.4 Demolition of Buildings or Structures It is anticipated that the demolition of buildings and structures will temporarily increase fugitive dust at FCS during decommissioning. Demolition activities will be conducted in an organized and methodical manner to avoid and minimize significant amounts of particulate and fugitive dust generation at one time during decommissioning. As demolition and loading of material occurs, the area exposed will be sprayed to minimize airborne dust and particulates. It is therefore anticipated that the demolition of buildings and structures will potentially create temporary impacts to air quality, but none that would be considered significant or adverse.

8.6.3.5.5 Shipments of Material to an Off-Site Location It is anticipated that truck traffic will be required to remove construction materials, debris, and equipment from the FCS. The removal of materials will take place during active decommissioning, and will be include varying periods of heavier and lighter activity. An average of eight trucks per day is estimated over the course of active decommissioning. This increase in total truck traffic when added to the Nebraska Department of Transportation average of 585 heavy vehicles per day from 2018, is lower than the truck traffic recorded while FCS was in service of 640 heavy vehicles per day [14].

Fugitive dust and small particulates generated from truck traffic will be the primary contributor of potential air quality impacts during this phase of decommissioning. All appropriate BMPs will be implemented and maintained throughout decommissioning to ensure that there is a minimal amount of impacts to air quality.

In addition to the current air monitoring program at FCS, all air emissions will be monitored during decommissioning activities (fugitive dust, equipment exhaust, etc.) and will continue to be monitored in accordance with the ODCM, which sets limits on doses caused by effluents, based upon the ALARA objectives of 10 CFR 50.34a, 10 CFR 50.36a, and Section IV.B.1 of Appendix I to 10 CFR 50. Effluents are reported annually to the NRC.

FCS complies with all applicable federal and state air quality regulations, including the requirements of the NDEQ, and will implement BMPs to minimize fugitive dust during demolition and decommissioning activities.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-18 No adverse impacts on air quality are expected from the implementation of decommissioning activities. Consequently, the potential impacts to air quality are bounded by the GEIS and considered Small.

8.6.3.6 Aquatic Ecology The environmental impact evaluation associated with aquatic ecology in section 4.3.5 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

The aquatic habitat at FCS includes the area in front of the intake structure integral to the Missouri River bank. Habitats associated with this area were previously disturbed during the initial construction of the facility. However, the implementation of decommissioning activities is not expected to disturb existing aquatic habitats, the flora and fauna of nearby streams and wetlands. The maintenance of the riverbank will allow the river and local aquatic habitats to be maintained.

Various fresh water fish species, macro-invertebrate populations, and vegetation exist within these aquatic environments and were identified during a study contracted by OPPD. OPPD performed a project decision model to assist with the decision for removing or leaving the Intake Structure and Circulating Water Discharge Tunnel at FCS. The project decision model concluded that the removal of the above ground structures and filling of the Lower Intake Structure and Circulating Water Discharge Tunnel should be completed. This decision resulted in the least impact to the environment, including aquatic ecology considerations.

Plans for the demolition of structures at FCS do not include the removal of waste or equipment by barge. Consequently, there is no impact to the riverbank from this type of activity.

OPPD will continue to maintain its NPDES permits and decommissioning operations will be performed within applicable NPDES limits. Furthermore, protection of the onsite and adjacent wetlands is, and will continue to be, a priority when planning any onsite dismantlement or waste management operation. In addition, the BMPs are implemented to prevent impacts to the aquatic systems.

Exotic species can threaten native species and ecosystems due to aggressive growth, reproduction or survival rate, and diseases or parasites they may transmit to native species. The decommissioning of FCS will not introduce any exotic plants or animals into the environment.

The potential impacts to the aquatic ecology within the site boundary are bounded by the GEIS and considered to be Small. The potential impacts to the aquatic ecology beyond the site boundary have also been evaluated and considered to be Small.

8.6.3.7 Terrestrial Ecology The environmental impact evaluation associated with terrestrial ecology in section 4.3.6 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

Direct impacts can result from activities such as clearing native vegetation or filling a wetland.

OPPD anticipates minimal disturbance of habitat beyond the operational areas of the plant. All

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-19 dismantlement, demolition, and waste staging activities are envisioned to be conducted within the operational area of the site. In addition, the NDEQ controls significant impacts to the environment through regulation of construction activities.

Indirect impacts may result from effects such as erosional runoff, dust, or noise. Any construction activities that would disturb one acre or greater of soil requires a storm water permit from the NDEQ prior to proceeding with the activity. The storm water permit contains BMPs to control sediment and the effects of erosion associated with the construction activity. Fugitive dust emissions will be controlled through the judicial use of water spraying.

Section 4.3.6 of the GEIS concludes that if BMPs are used to control indirect disturbances and habitat disturbance is limited to operational areas, the potential impacts to terrestrial ecology are Small. As discussed above, there are no unique disturbances to the terrestrial ecology anticipated during the decommissioning of FCS. Currently, FCS will be able to conduct all of these decommissioning activities on previously disturbed land. As required, the environmental impact will be reevaluated when activity is planned on previously undisturbed land. Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on terrestrial ecology are bounded by the GEIS.

8.6.3.8 Threatened or Endangered Species The threatened and endangered species are identified in the 2002 Environmental Report. In October 2018, a review for plant and wildlife species protected by the Nebraska Nongame and Endangered Species Act was requested by the Nebraska Game and Parks Commission. The conclusion of the reports indicate the terrestrial species that may be at or near the FCS include the following:

• three bird species: the federal and state threatened bald eagle (Haliaeetus leucocephalus) and piping plover (Charadnus melodus), the federal and state endangered least tern (Sterna antillarum)

• one reptile species: the state threatened massasauga rattle snake (Sistrurus catenatus)

• three plant species: the federal and state threatened western prairie fringed orchid (Plantanthera praeclara), the state threatened small white ladys-slipper (Cypripedium candidum) and American ginseng (Panax quinquefolium)

• three fish species: the federal and state endangered pallid sturgeon (Scaphirhynhcus albus), the state threatened lake sturgeon (Acipenser fulvescens) and sturgeon chub (Macrhybopsis gelida)

• The only new species that may be at or near FCS not listed in 2002 was identified in 2018. It was a mammal species: the federal and state threatened northern long-eared bat (Myotis septentrionalis).

Least terns and piping plovers nest on riverine sandbars within the central United States, including those present along the Missouri River. The loss of sandbar nesting habitat due to river channelization and changes in flow from the construction and operation of main-stem dams have resulted in population declines for both the least tern and the piping plover along the Missouri River.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-20 The amount of cooling water withdrawn from the Missouri River will significantly decrease, thus reducing the potential impacts of impingement, entrainment, and thermal discharges on aquatic species. One potential adverse impact from the decrease in cooling water withdrawn may be the elimination of the thermal refuge for aquatic species in the discharge area, which are preyed upon by the bald eagle in the winter months. Removal of the intake and discharge facilities as well as other shoreline structures will be conducted in accordance with BMPs outlined in permits issued by the NDEQ and the U.S. Army Corps of Engineers.

The historic range of the massasauga included eastern Nebraska and Washington County, but there are no recent records within 50 miles of FCS. Extant populations of the massasauga have been documented only in Colfax and Pawnee counties. This small rattlesnake prefers wet prairie habitat.

Two plant species are listed by the State of Nebraska, but not by the Federal Government. These include small white lady's-slipper (Nebraska-listed as threatened; occurs in wet meadows) and American ginseng (Nebraska-listed as threatened; occurs in high quality upland forest). The listed species are not known to occur on FCS.

The western prairie fringed orchid (federally listed as threatened) is found most often on unplowed, calcareous prairies and sedge meadows. It potentially occurs in Washington County, based on historic observations, but no populations are known to occur in the county, and the potential for occurrence on or near FCS is low given the lack of prairie habitat in these areas.

No designated critical habitat exists for any of the listed aquatic species on or in the vicinity of FCS. No aquatic species in the area is proposed for listing or is a candidate for listing. The FCS site is located within a reach of the Missouri River that has been channelized, with a relatively uniform width and swift current. This channel degradation results in a reduction of sediment and organic matter, flow modifications, and channel narrowing. As a result, it is believed that the cues for spawning are no longer present.

OPPD environmental personnel conduct monthly site environmental inspections to monitor for adverse environmental impacts and general environmental conditions including protected species. OPPD also has a plan in place for protection of the bats, as well as other mammals and birds that may be encountered in their service territory.

The environmental impacts during decommissioning are expected to be minimal on threatened and endangered terrestrial species. Additionally, FCS has administrative controls in place which require that significant project activities undergo an environmental review prior to the activity occurring, which ensures that impacts are minimized through implementation of BMPs and the OPPD Avian Protection Plan [15]. State permits are required, which include evaluation of the impacts to the environment and considerations of threatened and endangered species that may occur from the specific activity. Any necessary mitigation activities, should any be identified due to environmental consequences at the time, would receive the appropriate state permitting. This process also includes federal triggers to check for federal threatened and endangered species. No demolition at FCS would be allowed to proceed without the appropriate approval. Based on the above, the planned decommissioning of FCS will not result in a direct mortality or otherwise jeopardize the local population of any threatened or endangered species.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-21 The potential impacts to Threatened or Endangered species are bounded by the GEIS and considered Small.

8.6.3.9 Occupational Issues/Safety The environmental impact evaluation associated with occupational issues in Section 4.3.10 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact. While decommissioning involves increased industrial activities and safety focus, similar programs addressing worker safety were implemented during the operation of the facility and also during repair and refueling outages. The occupational issues and safety impacts assessed are those related to human health and safety, including impacts from physical, chemical, ergonomic, and biological hazards. Radiological impacts were previously discussed in Section 8.6.2.1.

OPPD and EnergySolutions are committed to decommissioning FCS safely, and OPPD has established the HASP to effectively control hazards in the work environment and prevent occupational injuries and illnesses. The HASP and OPPD/EnergySolutions comply with federal and state regulations including Nebraska Department of Labor and the U.S. Occupational Health and Safety Administration requirements. The HASP applies to all OPPD and EnergySolutions employees as well as visitors and contract personnel working under direct OPPD or EnergySolutions supervision.

Numerous safety practices and communications are conducted at the site and include, but are not limited to:

• Safety is emphasized as the first topic of discussion at meetings.

• All workers are provided a Health and Safety booklet.

• Worker training and required certifications are reviewed prior to assignment to tasks requiring specific worker qualifications. Certain specialty subcontractors are mobilized, as necessary.

• Safety Data Sheets are obtained and reviewed for chemicals brought on-site.

• Health and Safety staff are involved in reviewing and approving decommissioning work packages and participating in pre-job walk downs, work condition assessments, and reviews.

• Daily and weekly safety messages are issued as well as Safety Bulletins to communicate awareness of significant safety issues and lessons learned.

• Safety stand-downs are held whenever serious safety events occur to communicate and reinforce safety events and lessons learned site-wide.

Therefore, occupational issues/safety is evaluated to be bounded by the GEIS, and the impact is considered Small.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-22 8.6.3.10 Cost A detailed discussion of the site decommissioning project costs is presented in Chapter 7 of this LTP.

8.6.3.11 Socioeconomic Impacts OPPDs original decision to permanently cease plant operations was not subject to NRC review or approval. On June 16, 2016, the OPPD Board of Directors voted to permanently cease operations of FCS for financial reasons.

As FCS transitions from shutdown and into the different phases of decommissioning, an overall decrease in plant staff will occur. The lost wages of these plant staff may result in decreases in revenues available to support the local economy.

Although FCS may have some effect on the region as a whole, the vast majority of FCS employees have resided in Washington, Douglas, and Sarpy Counties. FCS employees may be expected to impact the economy the most in terms of real estate and consumer goods within the counties where they live. Therefore, any effects of FCSs closure are expected to be focused within these counties. Although effects outside of the counties are possible, if the effects within these counties are negligible, it is expected that effects in the surrounding areas are also negligible. Therefore, FCS closure should not have a significant adverse impact on the local economy in the years following closure.

Therefore, socioeconomic impacts are evaluated to be bounded by the GEIS, and the impact is considered Small.

8.6.3.12 Environmental Justice While low-income and minority populations are present in the vicinity of the former FCS, the percentages of low-income and minorities within the FCS census tract are lower than those in other surrounding county census tracts. No disproportionate impact to the greater population, including special groups, is expected.

An existing rail spur was modified to transport large components and other waste from FCS. The refurbished rail spur is used to transport waste over an existing route. Decommissioning activities will cause increases in truck traffic to and from FCS to transport equipment and debris.

The truck traffic will use existing highway and main street routes. Since a majority of the waste will be removed by rail, the increase in truck traffic will be temporary. There will be no environmental justice impact relative to rail and truck transportation as a result of decommissioning.

Based on the radiological environmental monitoring program data from FCS, the Supplemental Environmental Impact Statement (SEIS) determined that the radiation and radioactivity in the environmental media monitored around the plant have been well within applicable regulatory limits. As a result, the SEIS found that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations (i.e., minority and/or low-income populations) in the region as a result of subsistence consumption of water, local food, fish, and wildlife.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-23 There is no reason to believe that low-income and minority populations will be adversely impacted by the decommissioning project. Per the GEIS and this evaluation, the potential site-specific impact is considered Small.

8.6.3.13 Cultural, Historic, and Archaeological Resources Based on a review of the FCS property through the Nebraska State Historic Preservation Office (NSHPO) files and information provided by the applicant, the NRC concluded in Section 4.4.5 of the SEIS that the potential impacts from decommissioning of FCS on historic and archaeological resources would be Small.

FCS has an existing rail spur that was modified to ship waste and large components off-site.

Land disturbance for the removal of large components is minimized, because removal is primarily conducted via the site rail system.

A section of the plant site that lies north of the rail spur and is bounded on the southwest by U.S.

Highway 75 was determined as having Moderate to High Potential. It contains remnants of the former town of Desoto, Nebraska. Based on the impacts of past construction activities, the plant site being situated on floodplain alluvium, and having been developed since 1850, and the section of the site that lies south of the current Union Pacific rail spur should be categorized as having no potential for cultural resources, either prehistoric or historic.

Environmental review procedures have been put in place at FCS regarding undertakings that involve land disturbing activities in undisturbed surface and subsurface areas. These environmental protection procedures include contacting the NSHPO to establish the actions necessary to protect known or as of yet undiscovered cultural resources before an action is allowed to occur. The cultural, historic, and archaeological impact evaluation conducted in the GEIS focused on similar attributes as the SEIS. The GEIS evaluated direct effects such as land clearing and indirect effects such as erosion and siltation.

The conclusion for the license renewal evaluation is also applicable to the decommissioning period, because:

• decommissioning activities will be primarily contained to disturbed areas located away from areas of existing or high potential for archaeological sites,

• construction activities that disturb one acre or greater of soil are permitted by NDEQ approval, and BMPs are required to control sediment and the effects of erosion, and

• environmental protection procedures pertaining to archaeological and cultural resources will remain in effect during decommissioning.

Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on cultural, historic, and archaeological resources are Small and are bounded by the GEIS. Based on the historical information in the AEC Environmental Statement, the results of the reviews of historic, cultural, and archaeological resources performed in 2013 and 2014, current transportation methods for large components, and soil erosion control work practices, the decommissioning will have no significant impact on cultural and historic resources.

Archaeological resources would be Small.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-24 8.6.3.14 Aesthetics The environmental impact evaluation associated with aesthetics in Section 4.3.15 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

The impact of decommissioning on site aesthetics (e.g., visual skyline) is limited in terms of land disturbance and duration. These impacts are temporary and will cease when decommissioning is completed.

The location of the ISFSI is set back several hundred yards from the river frontage and located near the existing switchyard. Once all of the major plant structures and buildings on the riverbank are removed, aesthetics will improve by providing a more open view of the Missouri River. Restoration of the site to a more natural grade will result in a contiguous open view of the Missouri River.

Aesthetics will improve once the site is returned to open space. Therefore, the environmental impact associated with aesthetics is evaluated to be bounded by the GEIS, and the impact is considered Small.

8.6.3.15 Noise The environmental impact evaluation associated with noise in Section 4.3.16 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

FCS is located on the riverbank of the Missouri River. There are no residences within one half mile of the station, and no schools, hospitals, prison, motels, or hotels are in the immediate vicinity of the site. The center of the nearest community, Blair, Nebraska, is located approximately three miles to the northwest of the site.

Noise generation will primarily result from demolition activities involving heavy construction equipment. The noise from the shipment of waste will be minimal since the primary transportation method for shipment of LLRW will be by rail. Noise associated with decommissioning and shipment of waste is intermittent and temporary.

The ISFSI construction was completed in 2005. The ISFSI is a passive facility and there will be minimal noise generated from its operation. Once the decommissioning is complete, noise levels in the vicinity of the FCS site will be reduced to levels below those experienced during the operation of the facility.

Due to the distance of the station from sensitive receptors, there will be limited temporary impacts on noise levels during decommissioning and demolition activities. Therefore, the environmental impact associated with noise is evaluated to be bounded by the GEIS, and the impact is considered Small.

8.6.3.16 Irretrievable Resources During the demolition and structural dismantlement of the station, recycling and asset recovery efforts will be made. Some metals (e.g., from turbine, transformer components, etc.) have been released as clean scrap.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-25 Uranium is a natural resource that is irretrievably consumed during power operation. After the plant is shutdown, uranium is no longer consumed. The use of the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment, but rather a relatively short-term investment. Since the FCS site will be decommissioned to meet the unrestricted release criteria found in 10 CFR 20.1402, the land is not considered an irreversible resource. LLRW has been, and will continue to be, shipped to the EnergySolutions disposal site in Clive, Utah. This facility has sufficient space for the disposal of this waste. In addition, Class B/C waste that is generated may also be shipped to the Waste Control Specialists facility in Andrews, Texas.

As stated in the GEIS, irretrievable resources that would occur during the decommissioning process are the materials used to decontaminate the facility (e.g., rags, solvents, gases, and tools) and fuel used for construction machinery and for transportation of materials to and from the site.

These resource commitments are considered to be minor and are neither detectable nor destabilizing. Therefore, the environmental impact associated with irretrievable resources is evaluated to be bounded by the GEIS, and the impact is considered Small.

8.6.3.17 Traffic and Transportation The number of shipments and the volume of waste shipped are greater during decommissioning than during the operation of the facility. Non-radiological impacts of transportation include increased traffic and wear and tear on roadways. Because the majority of the waste will be transported by rail, the average number of daily shipments from the site will be relatively small.

Consequently, it is anticipated that there will be no significant effect on traffic flow or road wear.

The impacts of a transportation accident would be neither detectable nor destabilizing. Therefore, the environmental impact associated with traffic, transportation is evaluated to be bounded by the GEIS, and the impact is considered as Small.

8.6.3.18 Placement of Clean Concrete Demolition Debris and Sand Mix in Major Building Basements: Terrestrial Ecology and Transportation OPPD evaluated the use of clean concrete demolition debris for basement fill end state, and subsequently determined only clean fill is to be used.

8.7 Overview of Regulatory Governing Decommissioning Activities and Site Release 8.7.1 Federal Requirements Decommissioning activities that are subject to federal regulations include:

• spent fuel and GTCC storage at the ISFSI

• handling, packaging, and shipment of radioactive waste

• worker radiation protection

• license termination and final site release

• worker health and safety

• liquid effluent releases

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-26

• hazardous waste generation/disposition

• handling and removal of asbestos

• characterization and removal of polychlorinated biphenyls (PCBs)

• handling and removal of lead paint 8.7.1.1 NRC The majority of radiological activities falls under Title 10 of the Code of Federal Regulations and are administered by the NRC. Applicable Title 10 regulations include:

• Part 20 - Radiation protection

• Part 50 - Decommissioning activities

• Part 51 - Environmental protection

• Part 61 - Disposal of radioactive waste

• Part 71 - Packaging and transportation of radioactive waste (regulations in 49 CFR Parts 171 through 174 also apply)

• Part 72 - Licensing requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, and reactor-related GTCC waste

• Part 73 - Physical protection of plants and materials 8.7.1.2 EPA The EPA regulations outlined in Title 40 of the Code of Federal Regulations apply as follows:

• Part 61 - Asbestos handling and removal

• Parts 122 to 125 - NPDES

• Part 141 - Safe drinking water standards

• Part 190 - Radiation protection standards for nuclear power operations

• Parts 260 to 272 - Resource Conservation and Recovery Act

• Part 280 - Underground storage tanks

• Part 761 - Toxic Substance Control Act for PCBs

• Part 129-132 - Clean Water Act 8.7.2 State and Local Requirements Permits and approvals from or notifications to state and local agencies are required for safety and environmental protection purposes. Decommissioning activities and related site operations that fall under State and local jurisdiction include, but are not limited to, the following:

• Nebraska Department of Environmental Quality

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-27

• Nebraska Department Health and Human Services

• Nebraska State Historical Society This information provided above is a general overview of the applicable regulations and not intended to be all-inclusive.

8.8 Conclusion As previously evaluated in the FCS PSDAR, the non-radiological environmental impacts from decommissioning FCS are temporary and not significant. The potential issues identified as site-specific in NUREG-0586, Supplement 1 (such as Threatened and Endangered species and environmental justice) have been evaluated, and there is no significant impact. The potential environmental impacts associated with decommissioning FCS have already been predicted in and will be bounded by the previously issued environmental impact statements (PSDAR, NUREG-0586, and FCS Environmental Statement). Therefore, there are no new or significant environmental changes associated with decommissioning.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-28 8.9 References

[1] U.S. Nuclear Regulatory Commission, "Regulatory Guide 1.179, Revision 2, Standard Format and Contents for License Termination Plans for Nuclear Power Reactors, 2019.

[2] Updated Environmental Report Fort Calhoun Station File No. 127690-003" (LIC-20-0013, ML20202A654), March 2019.

[3] U.S. Atomic Energy Commission, Final Environmental Statement related to operation of Fort Calhoun Station Unit 1 (WIP 031037), March 1971.

[4] U.S. Nuclear Regulatory Commission, "NUREG-1437, Supplement 12, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Fort Calhoun Station Unit 1 - Final Report, 2003.

[5] Omaha Public Power District, Fort Calhoun Station Unit 1, Post Shutdown Decommissioning Activity Report.

[6] U.S. Nuclear Regulatory Commission, "NUREG-0586, Supplement 1, Volume 1, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, 2002.

[7] Correspondence, Olsson Engineering to the Army Corps of Engineers, February 2021.

[8] U.S. Nuclear Regulatory Commission, "NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities, 1997.

[9] U.S. Census Bureau American Community Survey report - 2010.

[10] Radiation Safety and Control Services, "TSD 20-001, Historical Site Assessment for Fort Calhoun Station, 2020.

[11] National Centers for Environmental Information, National Oceanic and Atmospheric Administration, www.ncdc.noaa.gov/stormevents/.

[12] Omaha Public Power District, "FCS-SAF-103, FCS Deconstruction Health and Safety Plan.

[13] Omaha Public Power District, "CH-ODCM-0001, Offsite Dose Calculation Manual.

[14] Nebraska Department of Transportation, gis.ne.gov/portal/apps/webappviewer/index.html?id=bb00781d6653474d945d51f49e1e7c34.

[15] Omaha Public Power District, "Avian Protection Plan".

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-29 Table 8-1 Summary of the Environmental Impacts from Decommissioning Section Environmental Issue GEIS Impact Onsite/Offsite Land Use 8.6.3.1

- Onsite Land Use Yes SMALL 8.6.3.2

- Offsite Land Use No Site Specific 8.6.3.3 Water Use Yes SMALL 8.6.3.4 Water Quality Surface Water Yes SMALL Ground Water Yes SMALL 8.6.3.5 Air Quality Yes SMALL 8.6.3.6 Aquadic Ecology Activities Within the Operational Area Yes SMALL Activities Beyond the Operational Area No Site Specific 8.6.3.7 Terrestrial Ecology Activities Within the Operational Area Yes SMALL Activities Beyond the Operational Area No Site Specific 8.6.3.8 Threatened and Endangered Species No Site Specific 8.6.2 Radiological Activities Resulting in Occupational Dose to Workers Yes SMALL Activiteis Resulting in Dose to the Public Yes SMALL Radiological Accidents Yes SMALL 8.6.3.9 Occupational Issues Yes SMALL 8.6.3.10 Cost*

N/A N/A 8.6.3.11 Socioeconomics Yes SMALL 8.6.3.12 Environmental Justice No Site Specific 8.6.3.13 Cultural and Historic Impacts Activities Within the Operational Areas Yes SMALL Activities Beyond the Operational Area No Site Specific 8.6.3.14 Astethics Yes SMALL 8.6.3.15 Noise Yes SMALL 8.6.3.17 Transportation Yes SMALL 8.6.3.16 Irretrevable Resources Yes SMALL 8.6.3.18 Placement of Clean Debris No Site Specific Note: Cost, Section 4.3.11 in GEIS Supplement 1, is not evaluated using environmental significance levels and is not identified as a generic or site-specific issue.

34 Pages Follow ATTACHMENT 3 Proposed License Termination Plan (Clean Chapter 8, Revision 2)

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN CHAPTER 8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT REVISION 2

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-i TABLE OF CONTENTS 8

SUPPLEMENT TO THE ENVIRONMENTAL REPORT............................................ 8-1 8.1 Introduction................................................................................................................... 8-1 8.1.1 Purpose...................................................................................................................... 8-1 8.1.2 Background................................................................................................................ 8-1 8.1.3 Proposed Action........................................................................................................ 8-2 8.1.3.1 Purpose of and Need for the Proposed Action............................................... 8-2 8.1.3.2 Alternative to the Proposed Action................................................................ 8-2 8.2 Site Location and Description....................................................................................... 8-2 8.2.1 Site Description after Unrestricted Release............................................................... 8-3 8.3 Remaining Dismantlement and Decommissioning Activities...................................... 8-5 8.4 Impacts to the PSDAR.................................................................................................. 8-5 8.5 Fort Calhoun Station Environmental Description......................................................... 8-6 8.5.1 Geography and Demography..................................................................................... 8-6 8.5.1.1 Site Location and Description........................................................................ 8-6 8.5.1.2 Population....................................................................................................... 8-6 8.5.1.3 Site Access, Land, and Water Use.................................................................. 8-7 8.5.1.4 Climate............................................................................................................ 8-7 8.5.2 Geology and Seismology........................................................................................... 8-8 8.5.3 Hydrology and Hydrogeology................................................................................... 8-8 8.6 Environmental Effects of Decommissioning................................................................ 8-9 8.6.1 Summary.................................................................................................................... 8-9 8.6.2 Radiological Effects of Decommissioning.............................................................. 8-10 8.6.2.1 Occupational Radiation Exposure................................................................ 8-10 8.6.2.2 Off-Site Radiation Exposure and Monitoring.............................................. 8-11 8.6.2.3 Environmental Effects of Accidents and Decommissioning Events............ 8-12 8.6.2.4 Storage and Disposal of Low-Level Radioactive Waste.............................. 8-12 8.6.2.5 Radiological Criteria for License Termination............................................. 8-13 8.6.3 Non-radiological Effects of Decommissioning....................................................... 8-13 8.6.3.1 On-Site Land Use......................................................................................... 8-13 8.6.3.2 Off-Site Land Use (in the Vicinity).............................................................. 8-14 8.6.3.3 Water Use..................................................................................................... 8-15 8.6.3.4 Water Quality............................................................................................... 8-15 8.6.3.5 Air Quality.................................................................................................... 8-16 8.6.3.5.1 Worker Transportation.............................................................................. 8-16 8.6.3.5.2 Dismantling Systems and Removal of Equipment.................................... 8-16 8.6.3.5.3 Movement and Open Storage of Materials On-Site.................................. 8-17 8.6.3.5.4 Demolition of Buildings or Structures...................................................... 8-17 8.6.3.5.5 Shipments of Material to an Off-Site Location......................................... 8-17

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-ii 8.6.3.6 Aquatic Ecology........................................................................................... 8-18 8.6.3.7 Terrestrial Ecology....................................................................................... 8-18 8.6.3.8 Threatened or Endangered Species............................................................... 8-19 8.6.3.9 Occupational Issues/Safety........................................................................... 8-21 8.6.3.10 Cost............................................................................................................... 8-22 8.6.3.11 Socioeconomic Impacts................................................................................ 8-22 8.6.3.12 Environmental Justice................................................................................... 8-22 8.6.3.13 Cultural, Historic, and Archaeological Resources........................................ 8-23 8.6.3.14 Aesthetics...................................................................................................... 8-24 8.6.3.15 Noise............................................................................................................. 8-24 8.6.3.16 Irretrievable Resources................................................................................. 8-24 8.6.3.17 Traffic and Transportation............................................................................ 8-25 8.6.3.18 Placement of Clean Concrete Demolition Debris and Sand Mix in Major Building Basements: Terrestrial Ecology and Transportation........................................ 8-25 8.7 Overview of Regulatory Governing Decommissioning Activities and Site Release.. 8-25 8.7.1 Federal Requirements.............................................................................................. 8-25 8.7.1.1 NRC.............................................................................................................. 8-26 8.7.1.2 EPA............................................................................................................... 8-26 8.7.2 State and Local Requirements................................................................................. 8-26 8.8 Conclusion................................................................................................................... 8-27 8.9 References................................................................................................................... 8-28 LIST OF TABLES Table 8-1 Summary of the Environmental Impacts from Decommissioning...................... 8-29

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-iii ABBREVIATIONS AEC Atomic Energy Commission ALARA as low as is reasonably achievable AMSL above mean sea level BMP best management practices CE Combustion Engineering CNW Chicago and Northwestern DCGL derived concentration guideline level DSAR Defueled Safety Analysis Report FCS Fort Calhoun Station FSS final status survey GEIS general environmental impact statement GTCC greater than Class C HASP health and safety plan IOF ISFSI Operations Facility ISFSI Independent Spent Fuel Storage Installation LTP license termination plan LLRW low-level radioactive waste MW megawatts NDEQ Nebraska Department of Environment Quality NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NSHPO Nebraska State Historic Preservation Office OCA Owner Controlled Area ODCM Off-Site Dose Calculation Manual OPPD Omaha Public Power District PCB polychlorinated biphenyls PSDAR Post Shutdown Decommissioning Activity Report PWR pressurized water reactor REMP Radiological Environmental Monitoring Program

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-iv RGPP Radiological Groundwater Protection Program RP radiation protection SEIS supplemental environmental impact statement SWPPP Storm Water Pollution Prevention Plan EPA U.S. Environmental Protection Agency

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-1 8

SUPPLEMENT TO THE ENVIRONMENTAL REPORT 8.1 Introduction In accordance with the requirements of 10 CFR 50.82(a)(9)(ii)(G) and the guidance of Regulatory Guide 1.179, Standard Format and Contents for License Termination Plans for Nuclear Power Reactors [1], this chapter provides a supplement to the environmental report describing any new information or significant environmental change associated with the site-specific decommissioning and site closure activities performed at the Fort Calhoun Station (FCS) site.

8.1.1 Purpose This chapter supplements the Omaha Public Power District (OPPD) Updated Environmental Report - Fort Calhoun Station as supplemented [2], describing any new information or significant environmental changes associated with the site-specific decommissioning and license termination activities presented in this License Termination Plan (LTP). The supplement includes a detailed description of the remaining decommissioning and site closure activities, the interaction between those activities and the environment, and the likely environmental impact of those activities. The supplement discusses whether the activities and their impacts are bounded by the impacts predicted by the U.S. Atomic Energy Commission (AEC) Final Environmental Statement related to operation of Fort Calhoun Station Unit 1 (AEC Environmental Statement)

[3]; NUREG-1437, Supplement 12, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Regarding Fort Calhoun Station, Unit 1 [4]; and the FCS Post Shutdown Decommissioning Activity Report (PSDAR) [5]. This chapter discusses decommissioning activities, with a focus on those activities to be performed from time of submittal of this LTP until the licensees completion of decommissioning activities.

8.1.2

Background

FCS is comprised of one 533.7 MWe pressurized water reactor (PWR) unit, with supporting facilities, which was operated by OPPD from 1973 to 2016.

The station was granted a construction permit by the AEC in 1968, and first commercial operation was achieved in 1973. OPPD made the decision to permanently shut down FCS due to a variety of factors, including economic analyses associated with production cost, economies of scale issues, and excess system supply. Permanent cessation of operations at FCS occurred on October 24, 2016. Certification of Permanent Defueled Status was achieved on November 13, 2016.

In accordance with the requirements of 10 CFR 50.82, OPPD submitted the initial revision of the PSDAR to the U.S. Nuclear Regulatory Commission (NRC) on March 30, 2017. The reactor at FCS remained in a SAFSTOR condition until December 16, 2019. At this point, the PSDAR was amended to address the acceleration of decommissioning activities, change the decommissioning schedule and cost milestones, and commit to notifying the NRC of the final disposition of the reactor closure vessel head. The amended PSDAR established the DECON method as the current decommissioning approach and described the accelerated decommissioning schedule with a lower revised cost estimate to reflect current knowledge and waste disposal options.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-2 The environmental impacts of decommissioning operations at FCS were assessed as part of the PSDAR submittal. The assessments included the evaluation of impacts against those noted in the AEC Environment Statement and NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (GEIS) [6]. The reference facility used from NUREG-0586 is an approximately 931 MWe PWR, operated by Maine Yankee Atomic Power Company and designed by Combustion Engineering (CE). The FCS PWR, designed by CE, had a much lower power output. With the power output of FCS lower than that of the reference plant, the use of the reference site will provide a bounded comparison of the generic environmental assessment.

The amended PSDAR concluded that the decommissioning of the FCS would be accomplished with no significant adverse environmental impacts and that the environmental impacts associated with the site-specific decommissioning activities for FCS would be bounded by previously-issued environmental impact statements.

8.1.3 Proposed Action The proposed action is the review and subsequent approval of the FCS LTP. This action was complete with the approval of Revision 1 of the FCS LTP; however, the action is revived to address the License Amendment Request for Revision 2 of the FCS LTP. LTP Revision 2 incorporates revised dose calculations for the Auxiliary Building basement, requirements for remediation, and survey methodologies.

8.1.3.1 Purpose of and Need for the Proposed Action The purpose of and need for the proposed action is to allow for completion of decommissioning of the FCS site, termination of the FCS operating license, and subsequent release of the FCS site for unrestricted use. The approval of the LTP ensures that final decommissioning activities are appropriately completed.

The FCS site intends to meet the criteria for unrestricted use. Chapters 5 and 6 of this LTP detail the final status survey (FSS) process and derived concentration guideline levels (DCGLs) used to demonstrate compliance with 10 CFR 20.1402. The site intends to use grout as fill material to eliminate groundwater in-leakage from foundation fractures and to mitigate dose. As such, LTP Revision 2 includes significant changes within Chapters 5 and 6 to several DCGLs and introduces grout DCGLs.

8.1.3.2 Alternative to the Proposed Action There is no alternative to the proposed action that would allow approval of the FCS LTP and subsequent release of the site for unrestricted use after demonstrating compliance with the release criteria specified in 10 CFR 20.1402.

8.2 Site Location and Description The FCS site is located on the southwest bank of the Missouri River at river mile 646.0, approximately 19.4 miles north of Omaha, Nebraska. LTP Chapter 1, Figure 1-1, shows the geographical location of the site relative to nearby towns, cities, and the river. OPPD has a

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-3 perpetual easement on approximately 117 acres of land primarily on the northeast bank of the river directly opposite the plant buildings.

FCS is situated within parts of Sections 16, 17, 20, and 21, Township 18 North, Range 12 East of Washington County, Nebraska in the Modale, IA quadrangle. The site is part of the Missouri River bottomland, which is a nearly level plain about 15 miles wide at Blair, Nebraska, 8 miles wide at the site, and narrowing to 3 miles wide in the vicinity of Omaha-Council Bluffs. On the southwestern part of the site, the ground rises sharply about 60 feet to a higher-level area, which is bounded on the south by U.S. Highway 75, formerly U.S. Highway 73.

The elevation of this plain averages about 1,000 feet above mean sea level (AMSL) at the site.

The surface of the land, starting from the Missouri River at about 997 feet AMSL, falls to an old channel of the river before rising again to approximately 1,004 feet AMSL. Beyond this point, the land then gradually falls off to about 1,000 feet AMSL, rises again to approximately 1,020 feet AMSL, and then rises approximately 60 feet to a higher plateau at elevation 1,080 feet AMSL. LTP Chapter 1, Figure 1-4, provides a depiction of the FCS site topography.

The site is comprised of approximately 660 acres, which is owned or controlled by OPPD. A portion of the property has been previously removed from the FCS License but is maintained under OPPD ownership. LTP Chapter 1, Figure 1-2, provides a depiction of the FCS Owner Controlled Area (OCA).

A rail spur from the Chicago and Northwestern (CNW) Railway was constructed to serve the construction of the FCS. The original CNW tracks and rail spur have since been removed. In 1994, a permanent easement was granted to allow the construction of a new rail spur in the approximate location of the old CNW railway to allow trains to serve the Cargill industrial facility located north of FCS. In late 2020, OPPD added three lines (Lines A, B, and C, approximately 1,360, 1,595, and 2,230 feet in length, respectively) to the rail spur to allow for the direct loading of waste into rail cars. The added rail lines will remain in place after license termination with the exception of the portion of the line that resides within the waste processing structure.

8.2.1 Site Description after Unrestricted Release This section provides a summary of the final condition of the site at the conclusion of decommissioning and site closure activities. The End State is defined as the configuration of the remaining below-ground basements, above-ground structures, piping, and open land areas at the time of license termination. Chapters 3 and 6 of the LTP provide more detailed discussions of the FCS end state.

The following above-ground buildings will remain at the time of license termination: Training Center, FLEX Building, OCA Entrance Building, 3451 Old Building, 3451 New Building, and the 1251 Control and Switchgear Building. With the exception of the removal of the 345kv and 161kv lines to the station, the Switchyard will remain after decommissioning. All other structures will be removed to a minimum of three feet below grade (approximately 1,001 feet AMSL). Because there are no dose model implications, if the number and identification of above-ground buildings to remain and be subject to FSS changes, the NRC will be notified.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-4 For the Containment Building basement, all concrete will be removed from the inside of the steel liner, leaving only the remaining exposed liner below 1,001 feet AMSL and the structural concrete outside of the liner. In the Auxiliary Building basement, all internal walls and floors below 1,001 feet AMSL will be removed, leaving only the reinforced concrete floors and outer walls of the building structures. In the Turbine Building, all interior walls and floors below 1,001 feet AMSL will be removed with the exception of the turbine pedestals. For the Spent Fuel Pool, the only portion of the structure that will remain is the lower pool below the 1,001 feet AMSL and the concrete structure of the Fuel Transfer Canal after the steel liner has been removed.

There are additional below-ground structures that will remain, including the lower concrete portions of the Circulating Water inlet piping and Circulating Water discharge tunnels.

An evaluation was performed regarding the disposition of the Intake Structure. The option to leave the structures basement in place below 1,001 feet AMSL and backfill was determined to be the least disruptive to the environment. The impact of leaving the Intake Structure and intake and discharge piping in place is discussed in a correspondence developed by Olsson Engineering with the Army Corps of Engineers [7].

For all excavations created by the removal of buried piping, components, or slab-on-grade structures, a radiological assessment will be performed prior to backfill. For all below-ground basements that will remain, an FSS will be performed, and contingent upon the completion of confirmatory surveys and regulatory approval, the basements will be backfilled. If a major below-ground building has been removed in its entirety, an FSS will be performed on the resultant excavation (using the most-restrictive classification of the building prior to demolition) prior to backfill of the excavation. All void spaces will be backfilled using clean fill material to grade (1,004 feet AMSL). An exception to this would be the use of grout to fill the trenches of the Auxiliary Building 989 feet elevation and the Stressing Gallery. The end state will also include a range of buried piping, embedded piping, and penetrations. All buried piping that is abandoned in place will be capped and/or filled with grout. The restored areas on the site will be backfilled, graded, and returned to natural contours. The demolition debris will be segregated for recycling or disposal.

The ISFSI, ISFSI Operations Facility (IOF), and support structures will remain in the reduced 10 CFR Part 50 license and are not within the scope of the proposed partial site release.

Several structures will remain at the end state as requested by OPPD. These structures are as follows:

• OPPD Electrical Switchyard and supporting structures (note: the Switchyard will remain in active use after decommissioning in support of the existing OPPD off-site electrical transmission and distribution system)

• FLEX Building

• Training Center

• Training Center - Sanitary Sewage System

• OCA Entrance Building

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-5

• Paved roadways and rail lines, including the lines and rail spur constructed in 2011 and 2020, allowing for rail service at the site via connection to the nearby Union Pacific railway After all demolition and remediation activities are compete, OPPD will use the FSS process described in Chapter 5 of this LTP to demonstrate that the FCS and surrounding open land areas, with the exception of the ISFSI, comply with radiological criteria for unrestricted use specified in 10 CFR 20.1402. As part of the decommissioning process, all reactor fuel was loaded into casks and transferred to the ISFSI. The greater than Class C (GTCC) waste will be segregated and transported for storage in the ISFSI. It is expected that the fuel will remain on-site in dry storage within the ISFSI until it is transferred as determined by the U.S. Department of Energy.

The ISFSI, which occupies approximately 6.5 acres, was constructed in the northwest corner of the previous FCS protected area, northeast of the OPPD switchyard.

Following the conclusion of radiological remediation activities and prior to initiating final survey, isolation and control measures will be implemented. The control measures will be implemented to ensure the final radiological condition is not compromised by the potential for recontamination as a result of access by personnel or equipment. Open land areas, access roads, and boundaries will be posted with signs restricting access. Isolation and control measures will be implemented through approved plant procedures and will remain in force throughout FSS activities, until there is no risk of recontamination from decommissioning or the survey area has been released from the license.

Several services, such as the Blair City water service and OPPD electrical service, will remain in operation to support the ISFSI monitoring and security operations. The station monitoring wells will remain in service for continued periodic sampling. There are no potable wells in service on site. Water service is provided through the City of Blair municipal water supply which draws water from the Missouri River via a water intake about 5 miles north of the site.

The Missouri River, which flows generally north to south, forms the northeast to southeast site boundary. This part of the river is referred to by the Army Corps of Engineers as the Blair Bend.

The river limits are under control of the Army Corps of Engineers who have established a structure azimuth line, which acts as another site boundary.

8.3 Remaining Dismantlement and Decommissioning Activities Key dismantlement and decommissioning activities that have been completed include activities associated with the removal of system piping and components, the segmentation and packaging of the internals from the FCS reactor, and the demolition and disposal of several ancillary structures.

Chapter 3 of this LTP provides details on the dismantlement, demolition, and remediation activities currently performed and remaining activities to be executed to achieve the end state condition.

8.4 Impacts to the PSDAR The PSDAR, amended in December 2019, describes the planned decommissioning operations at the site and concludes that the potential environmental impacts associated with decommissioning

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-6 the site have already been postulated in, and will be bounded by, the previously issued environmental impact statements, specifically:

• Final Environmental Statement, as amended and supplemented

• NUREG-0586

• NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities [8]

Chapter 3 of this LTP identified the dismantlement and decontamination activities that are scheduled to be completed prior to unrestricted release of the site (excluding the ISFSI footprint).

These identified activities are not significantly different from what was proposed in the PSDAR.

Although additional details regarding major decommissioning activities will be defined during ongoing decommissioning planning efforts, no significant impacts beyond those identified in the PSDAR have been identified. Subsequent sections in this chapter provide additional evaluation and information regarding the environmental effects of decommissioning.

8.5 Fort Calhoun Station Environmental Description 8.5.1 Geography and Demography 8.5.1.1 Site Location and Description The site location and description were previously discussed in Section 8.2. FCS is situated within parts of Sections 16, 17, 20, and 21, Township 18 North, Range 12 East of Washington County, Nebraska in the Modale. IA quadrangle. The site is part of the Missouri River bottomland, which is a nearly level plain about 15 miles wide at Blair, Nebraska, 8 miles wide at the site, and narrowing to 3 miles wide in the vicinity of Omaha-Council Bluffs. The elevation of this flood plain averages about 1,000 feet AMSL at the site. On the southwestern part of the site, the ground rises sharply about 60 feet to a higher, level area, which is bounded on the south by U.S.

Highway 75, formerly U.S. Highway 73. The topography at the site ranges from approximately 997 feet to 1,080 feet AMSL and represents a river bottom deposit along the Missouri River subsequent to the most recent period of glaciations.

8.5.1.2 Population According to the U.S. Census Bureau American Community Survey report from 2010 [9], the population of Washington County is 20,234. The nearest municipality is the city of Blair, Nebraska, about three miles northwest, with a population of 7,990. Fort Calhoun, Nebraska, is about five miles southeast with a population of 908. Kennard Village, Nebraska, about seven miles from the plant site has a population of 167. Omaha, Nebraska, and Council Bluffs, Iowa, metropolitan area is 10 to 25 miles southeast of the site with a majority of the population beyond the 15-mile radius from the site with a population of 789,342. Missouri Valley, Iowa, about 11 miles east, has a population of 2,838.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-7 8.5.1.3 Site Access, Land, and Water Use The remaining site encompasses approximately 540 acres and is located on the alluvial plain of the Missouri River in a predominantly agricultural region roughly ten miles north of the Omaha metropolitan area. The site is relatively isolated and is bordered to the northwest by an industrial facility and farm fields, to the southeast by farm fields, to the south by a state highway with scattered residence, and to the north by the Missouri River, farm fields, and a wild life refuge area. The Missouri River is also used for commercial barge and recreational boat traffic.

According to the Historical Site Assessment for Fort Calhoun Station [10], there are no residences within 0.5 miles of FCS, as measured from the center of the Auxiliary Building stack.

The seven nearest residences are from 3,000 to 4,000 feet distant. There are no schools, hospitals, prisons, motels, or hotels in the immediate vicinity of the site.

8.5.1.4 Climate Nebraska is located midway between two distinctive climate zones, the humid east and the dry west. Cyclic weather conditions representative of either zone, or combinations of both, occur.

Changes in weather result from the invasion of large masses of air with dissimilar properties.

These air masses tend to get their characteristics from either the warm and humid south-southeast, the warm and dry southwest, the cool and dry north-northwest, or the cold continental polar air of the north. The region is also affected by many storms or cyclones (areas of low pressure) which travel across the country, generally from west to east. Periodic and rapid changes in the weather are normal, especially in the winter. The mean annual temperature for the region is 51.1 degrees Fahrenheit. The January monthly mean is 20.2 degrees Fahrenheit, while that for July is 77.7 degrees Fahrenheit.

Annual average precipitation for the region is about 28.5 inches, but annual amounts vary widely from year to year. About 75 percent of the precipitation occurs during showers and thunderstorms from April through September. Snowfall amounts to about 30 inches of snow as the annual average, but total annual amounts vary widely from year to year.

The surface wind direction and speed are quite varied during all seasons of the year. The prevailing wind direction from May through December is from south-southeast; north-northwesterly winds prevail during the remainder of the year. The mean annual wind speed is 10.6 miles per hour.

Tornado events in the counties surrounding FCS since 1950 include: Washington County, NE, recorded 19 events, Douglas County, NE, recorded 20 events, Pottawattamie County, IA, recorded 42 events, and Harrison County, IA, recorded 23 events. On June 7, 1953, a category F2 tornado, 5.7 miles away from the FCS, injured one person and caused an estimated $25,000 in damages. On May 6, 1975, a category F4 tornado, 16.9 miles away from FCS, killed three people, injured 133 people, and caused approximately $250,000,000 in damages. There has been no reported tornado causing damage within five miles of the Station (Source: National Centers for Environmental Information, NOAA website [11]).

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-8 8.5.2 Geology and Seismology The soils below FCS include thick beds of limestone, dolomite, shale, sandstone, and thin layers of coal beds. The deeper formations were deposited in marine depositional environments with the shallow soils from the lateral migration of the paleo river channel. The major tectonic features of the mid-continent region began to develop late in the Paleozoic Era, and probably most of the important structural features of the Nebraska-Iowa Missouri River Valley area had already developed or were developing by the end of Permian period. However, there is no record of movement of the fault in historic times, or any indication of activity in recent geologic time.

At the beginning of the Pleistocene period, the Missouri River Valley and its main tributaries were established in their approximate present positions. Subsequently, under successive glacial movements, the valleys were filled and re-opened several times. During this period, the Peorian loess was deposited on the terraces and adjacent uplands. It is probable that only the upper part of the alluvium in the Missouri River Valley is actually of recent age and that deeper deposits are mostly of Pleistocene age.

According to the Defueled Safety Analysis Report (DSAR), unconsolidated sediments at the plant site generally range from 65 to 75 feet in thickness. The soils are typically interstratified and cross-bedded. These soils may be grouped generally into two units:

• an upper fine-grained sandy clay with silt approximately 20 to 50 feet thick

• an underlying carbonate bedrock surface at a depth of approximately 65 to 75 feet below ground surface The upper units were representing former river deposits and are not likely continuous, but rather have preferential channels formed by paleo-oxbow deposits.

Pennsylvanian-aged limestone and shale (bedrock) of the Kansas City Formation are encountered below the overburden soils. The bedrock below the site consists of various types of limestone formations.

The site lies in a region of infrequent seismic activity. Since the middle of the 19th century, from the first historical record of earthquake occurrence in the area, only 13 shocks with epicentral Modified Mercalli Intensities of V or greater have occurred within 200 miles of the plant site.

Only one earthquake of Modified Mercalli Intensity VI has been reported within 200 miles of the site. It occurred in March 1935, near Tecumseh, Nebraska.

8.5.3 Hydrology and Hydrogeology Water levels recorded at the site show that the groundwater gradients are nearly flat, with only a gentle slope toward the river, about 10 feet below the ground surface. Water levels at the site varied from elevations 993.7 to 992.4 feet, while the river levels recorded during this same period ranged from elevations 993.2 to 992.4 feet. Groundwater levels vary with changes in the river level. The rate of groundwater flow in the alluvial soils varies with the permeability; however, the groundwater flow rate, or velocity, is very slow due to the low gradients. The coefficient of permeability varied from about 0.5 to 3 feet per day in the upper sandy silt and

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-9 silty sand. In the lower fine-to-coarse sands and gravels, coefficients of permeability as high as 20 feet per day were measured.

According to the DSAR, groundwater flow directions have been reported to be both toward the Missouri River (northeasterly) and away from the Missouri River (south-southwesterly). Flow directions towards the river appear to represent times when Missouri River levels are relatively low (e.g., during the spring, summer, and early fall, when most precipitation occurs and the river flow is relatively high). Flow directions away from the river appear to represent times when Missouri River levels are relatively high, causing bank storage effects (e.g., during late fall and winter when the river recedes).

The FCS site is bounded on the northeast and southeast by a portion of the Blair Bend of the Missouri River. The Corps of Engineers maintains river structures to prevent further meandering of the channel within the alluvial flood plain; the structures take the form of pile dikes and revetments.

Fish Creek is an intermittent drainage stream that runs along the northwest boundary of the ISFSI Protected Area, which is on the northwest boundary of the deconstruction area. This stream discharges into a larger wetland, before flowing in the Missouri River.

8.6 Environmental Effects of Decommissioning 8.6.1 Summary The evaluation and methodology of the environmental effects (or impacts) of the decommissioning of FCS follows the approach outlined in the GEIS. This approach includes identification of environmental issues as either generic or site-specific. If the issue is considered generic, it is assigned a significance level of either Small, Moderate, or Large. If identified as generic, the environmental impact is considered to be bounded by the evaluation in the GEIS, which concludes that the impact significance is Small. In this event, site-specific evaluation by licensees is generally not required.

For those environmental issues or decommissioning activities that require site-specific evaluation, a standard approach is followed. It is summarized as follows:

1)

The issue or activity is summarized including a summary of the impacts as reported in the original Environmental Statement (ES) and PSDAR. Note that many decommissioning activities are not identified in these documents.

2)

Applicable regulations, permits, limits or other regulatory requirements are identified.

3)

Potential impacts from decommissioning activities relating to the environmental issue are described.

4)

An evaluation is performed. This includes analysis and professional judgment to estimate or determine whether the activity is likely to make a noticeable impact on the environment considering the available information. If an impact is likely, existing and additional mitigation measures that can be taken are evaluated. If an impact cannot be avoided, a determination is made as to whether the impact is likely to seriously damage the resource or attribute.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-10

5)

A conclusion is reached. A conclusion is derived from the evaluation steps summarized above. The conclusion identifies the level of significance of the impacts. Site-specific issues are not bounded by the GEIS evaluation.

Table 8-1 was used as the basis for the site-specific environmental impact assessment for FCS. It is excerpted from Table 6.1 of NUREG-0586, Supplement 1. The first step in this process is to screen the issues to identify those that are site-specific. Decommissioning activities specific to FCS are then reviewed, and the activities that may require site-specific evaluation are identified.

The screening identified the following:

• off-site land use activities: changes in demographics and zoning that have occurred in the past 40 years

• aquatic ecology affected by activities beyond the operational area: changes in designation of sensitive areas (local wetlands and Missouri River bank)

• terrestrial ecology affected by activities beyond the operational area: changes in designation of sensitive areas (local wetlands and Missouri River bank)

• threatened and endangered species: changes in local flora and fauna and designation of threatened and endangered species that have occurred in the past 40 years

• environmental justice: changes in demographics and socioeconomic status in the past 40 years

• cultural and historic resource impacts beyond the operational areas: changes in local historic landmark designations and other cultural resources The following decommissioning activities, which required evaluation of impacts across several environmental attributes or issues, were identified:

• rail line upgrade and extension (on-site)

• Circulating Water inlet and outlet piping disposition impact on aquatic ecology (within and beyond the operational area) 8.6.2 Radiological Effects of Decommissioning 8.6.2.1 Occupational Radiation Exposure During decommissioning, OPPD has implemented, and will continue to implement, a Radiation Protection (RP) Program in accordance with the license specifications and the requirements of 10 CFR Part 20. The objectives of the RP Program are to control radiation hazards, avoid accidental radiation exposures, maintain occupational worker exposures to less than the administrative limit of less than 2,000 mrem/year total effective dose equivalent, and to maintain doses to workers and the public as low as is reasonably achievable (ALARA).

On October 24, 2016, OPPD placed FCS in a SAFSTOR condition (a period of safe storage of the stabilized and defueled facility). The reactor at FCS remained in a SAFSTOR condition until December of 2019, when FCS changed the decommissioning method to DECON. This period allowed for the decay of most short-lived radionuclides, which subsequently, reduced radiation

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-11 levels at the facility. This, combined with the effective implementation of the RP Program and ALARA measures, minimizes the projected and actual occupational radiation dose exposure during the decommissioning of FCS. It is anticipated that the most significant contributors to occupational dose from remaining dismantlement activities is the segmenting, packaging, and shipping of the reactor vessel internals and the reactor vessel.

The GEIS estimates that 560 to 1000 person-rem would be needed to decommission a PWR. The current occupational dose expended and dose expected to complete decommissioning for FCS is estimated to be approximately 285 person-rem. This is below the GEIS estimate.

As the occupational dose for the decommissioning will meet the regulatory standards of 10 CFR 20, it is therefore bounded by the criteria in the GEIS, and the impact is considered Small.

8.6.2.2 Off-Site Radiation Exposure and Monitoring OPPD implements a regulatory compliant Radiological Environmental Monitoring Program (REMP) at FCS, which provides annual reports with an accurate assessment of the radiological environment in and around the environs of the site. The REMP provides assurance that the radioactive gaseous and liquid effluent releases during plant operations do not exceed the concentration limits of 10 CFR 20, the dose limits of 10 CFR 50, Appendix I, or the fuel cycle dose limits of 40 CFR 190. OPPD and EnergySolutions will continue to adhere to these limits throughout the course of the decommissioning.

At FCS, the Circulating Water Discharge Tunnel is the main authorized effluent release pathway for the discharge of treated and filtered radioactive liquid waste to the Missouri River. Liquid effluents are monitored and sampled prior to release from on-site storage tanks.

The gaseous pathway analysis is subject to the meteorological conditions during the time of the release. Due to plant shutdown and cessation of noble gas and other radionuclide generation, gaseous effluents do not present a significant release or exposure pathway. Routine air sampling is performed to determine the dose due to radioactive gaseous releases.

The direct radiation exposure is measured continuously with the use of passive monitoring devices. The dose is integrated over three months to accumulate a statistically significant exposure.

The design basis for the ISFSI precludes airborne radioactive releases during spent fuel storage and provides adequate shielding to minimize exposure. Radiation monitoring for the ISFSI is performed in accordance with the RP Program implemented at FCS. In accordance with the worst-case scenario in the design basis, the projected doses at the site boundary are substantially below the limits established in 10 CFR 72.106(b) where there is total loss of the confinement barrier. Exposure from the ISFSI to the nearest permanent resident will not exceed 25 mrem/year as specified in 10 CFR 72.104 and 40 CFR Part 190.

Consequently, the public dose from decommissioning is bounded by the criteria in the GEIS, and the impact is considered Small.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-12 8.6.2.3 Environmental Effects of Accidents and Decommissioning Events Decommissioning accident analysis is integral to the licensing design basis for FCS. While decommissioning radioactively contaminated structures, systems, and components at FCS, it is necessary to assure the safety of the public in the surrounding area and workers. Worker safety is addressed in the RP and Safety programs for the FCS decommissioning project, which rely on ALARA principles and the FCS-SAF-103, FCS Deconstruction Health and Safety Plan (HASP) [12]. The safety of the public is principally related to potential hazards associated with an airborne release of radioactive materials during decommissioning operations.

During decommissioning, FCS will perform decontamination and dismantlement of structures, systems, and components in addition to maintenance, waste management, and surveillance. The accidents discussed in NUREG-0586, Supplement 1 associated with immediate dismantling would also be applicable during the decommissioning of FCS. However, the potential consequences associated with those accidents would be less at FCS because of the reduction of the total radionuclide inventory at FCS due to:

• decontamination efforts made before decommissioning,

• prior radioactive waste shipments, and

• radioactive decay.

Consequently, the potential decommissioning accidents at FCS are bounded by the accident evaluation presented in NUREG-0586, Supplement 1.

Operational accidents during decommissioning could result from equipment failure, human error, and service conditions. With the spent nuclear fuel located in the ISFSI, operational accidents during decommissioning can be categorized as follows:

• radioactive waste transportation accidents

• explosions and/or fires associated with explosive and/or combustible materials

• loss of contamination control

• natural phenomena

• human caused events external to FCS These potential operational accidents during decommissioning are addressed in NUREG-0586, Supplement 1 for immediate dismantlement and, consequently, are bounding for the decommissioning of FCS.

8.6.2.4 Storage and Disposal of Low-Level Radioactive Waste The decommissioning of FCS has required, and will continue to require, the disposal of large volumes of low-level radioactive waste (LLRW), including contaminated equipment, tools, clothing, and bulk debris materials such as concrete, metal, and asphalt. Materials that cannot be free released are, and will continue to be, dispositioned as LLRW. Through the proper implementation of the Waste Management Program, Process Control Program, and associated

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-13 procedures, OPPD ensures the appropriate segregation, classification, processing, packaging, shipment, and control of solid, liquid, and gaseous radioactive wastes.

The majority of the Class A LLRW from FCS will be shipped to the EnergySolutions disposal site in Clive, Utah. No significant impacts are expected from the disposal of LLRW. The total volume of LLRW for disposal was estimated in the Decommissioning Plan to be approximately 6,000,000 cubic feet. Actual waste volumes and classifications may vary. The vast majority of waste will be loaded into 8-120A or 3-60B casks, gondola rail cars, or articulating bulk cars and shipped to Clive, Utah. Oversized or overweight components, such as the reactor vessel head, are shipped using multiple axle tractor/trailer rigs or special rail cars. Rail and truck shipments are made in accordance with U.S. Department of Transportation regulations.

OPPD completed the construction of the ISFSI in 2005 with initial loading of 10 dry storage casks (DSC) commencing in August 2006 and completed in August 2009. The final spent nuclear fuel cask loading campaign started in October 2019 and concluded in May 2020. OPPD completed the transfer of all its spent nuclear fuel contained in 40 DSCs to the ISFSI, in May 2020. The multi-purpose fuel canisters within the casks are seal-welded and leak tight; therefore, no leakage is expected during normal operation, off-normal conditions, or design basis events. The storage of the fuel at the ISFSI does not generate any gaseous, liquid, or solid radioactive waste. The spent nuclear fuel will remain in storage at the ISFSI under the Part 50 license until the fuel is transferred to a permanent repository. GTCC waste will be stored in two seal-welded leak tight canisters within storage casks co-located at the ISFSI with the spent fuel.

8.6.2.5 Radiological Criteria for License Termination Following the completion of decontamination, dismantlement, and remediation activities, radiological surveys will be performed to demonstrate that the dose from any residual radioactivity remaining in as-left structure basements and soils at FCS (excluding the ISFSI) meets the unrestricted release criteria specified in 10 CFR 20.1402. Once the balance of the site is remediated and the as-left radiological conditions are demonstrated to be below the unrestricted release criteria, the 10 CFR Part 50 license will be reduced to the area around the ISFSI. LTP Chapter 5 and Chapter 6 provide the methodology for demonstrating compliance with the unrestricted release criteria.

8.6.3 Non-radiological Effects of Decommissioning 8.6.3.1 On-Site Land Use The environmental impact associated with on-site land uses have been determined by the NRC within Section 4.3.1 of NUREG-0586, Supplement 1 to be generically considered as a Small impact.

The decommissioning project is located and executed within the remaining boundary of the FCS property previously used for power generation. Some on-site roads have been refurbished, and a reinforced heavy haul path was constructed to support the transfer of radioactive waste to the rail tent. No barge slips are being utilized. The rail was originally installed during the construction of the station and was modified to support decommissioning activities. On-site land activities such as vehicle parking and equipment/container laydown, storage, staging, and waste loading occur,

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-14 and continue to occur, in a manner similar to when the facility was operational. Several structures such as the Switchyard, ISFSI, IOF, FLEX Building, Training Center, as well as all roadways and a majority of rail lines, will remain at license termination.

Uncontaminated concrete and other demolition debris, where radiological surveys demonstrate that the concrete is free of plant-derived radionuclides above background will be disposed of as clean waste. Demolition debris found to be contaminated or potentially contaminated based on process knowledge will be disposed of as LLRW. Consequently, the burial of demolition debris contaminated with residual radioactivity will not have the potential to affect land use and ground or surface water quality.

As during the operation of the facility, decommissioning activities have not been conducted in wetlands. The wetlands around the plant have been protected in accordance with environmental regulations and permits.

There is no information pertaining to any significant environmental changes associated with the site-specific decommissioning activities. Site closure will comply with applicable U.S.

Environmental Protection Agency (EPA) regulatory requirements.

In accordance with the guidance presented in the GEIS, the potential impacts to land use onsite are considered Small.

8.6.3.2 Off-Site Land Use (in the Vicinity)

Only areas within the existing site boundary will be used to support decommissioning and license termination activities (such as temporary storage and staging areas). Appropriate isolation and control measures will be instituted to prevent the spread of contamination. These measures will also be monitored to ensure their effectiveness. Thus, no environmental impacts associated with the use of off-site lands are anticipated from the decommissioning activities at FCS.

Of the 660-acre site, approximately 119 acres is designated as part of the area to be decommissioned. The remaining land belonging to OPPD contains structures, is part of the open area, or has already been released.

It is assumed that construction activities will disturb one acre or greater of soil and requires a National Pollution Discharge Elimination System (NPDES) Construction Storm Water General Permit from the Nebraska Department of Environment Quality (NDEQ) and possible NRC notification, prior to proceeding with the activity. OPPD has a Storm Water Pollution Prevention Plan (SWPPP) for decommissioning and construction activities at the FCS site. The SWPPP contains best management practices (BMPs) to avoid and/or minimize sediment and erosion discharges to watercourses and wetlands. All BMPs will be in place prior to initiating decommissioning/construction activities.

Once decommissioning is complete, decommissioned areas at FCS will be either be left as a gravel/paved area with appropriate permanent storm water controls left in place or restored back to grassland; therefore, there will be a net gain in undisturbed area at FCS and no significant adverse impacts to land use as a result of decommissioning.

Decommissioning activities are not being performed in areas defined as environmentally sensitive within the site boundary, nor in land which adjoins similar off-site land areas.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-15 Consequently, the off-site land areas are not affected by the decommissioning activities and the potential impacts to land use off-site are considered Small.

8.6.3.3 Water Use In accordance with Section 4.3.2 of NUREG-0586, Supplement 1, the environmental impact associated with water use has been determined to be generally applicable with a Small impact.

FCS is located on the bank of the Missouri River, and the Intake Structure affects approximately 80 feet of riverbank. The predominant water usage during the operation of FCS was the use of water from the Missouri River as secondary cooling water for the reactor systems. With the plant shutdown and fuel removed from the reactor and located in the ISFSI, the remaining use of the river is for dilution of released liquid waste. The use of water from the Missouri River during decommissioning activities is significantly less than the usage during operations.

Water from the Missouri river is used extensively for municipal and domestic water supplies.

There are multiple potable water intakes located on the Missouri river near FCS. The nearest substantial upstream intake is located about 1 mile northwest of the FCS site and downstream intake approximately 20 miles from the site. The City of Blair provides potable water services to support FCS. Potable water use during decommissioning operations is not expected to be greater than the potable water use experience during operations. The IOF sewage system is self-contained and does not release to the environment at the site. The Training Center will utilize a new on-site sewage waste system. Released wastewater will continue to be processed in accordance with the sites NPDES permits.

Consequently, in accordance with the GEIS, the potential impacts to water use are considered Small.

8.6.3.4 Water Quality The environmental impact evaluation associated with surface and groundwater quality in section 4.3.3 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

This section evaluates potential project effects on those portions of the natural environment related to surface water and groundwater. Surface water generally refers to streams, rivers, ponds, reservoirs, and lakes. At FCS, the nearby bodies of water are the Missouri River, surface streams near the site, including Fish Creek (immediately northwest of the IOF), Long Creek (0.7 miles southeast), DeSoto Lake (1.8 miles east), and the surrounding wetlands.

At FCS, all non-radiological water discharges to Fish Creek and the Missouri River are controlled under NPDES permits, including Storm water Discharges from Industrial Activity, Industrial, and General NPDES Permit Authorizing Dewatering Discharges Activity. These permits were issued by the NDEQ. In addition, impacts are greatly reduced through implementation of appropriate BMP for soil erosion and sedimentation control. There is no impact to the nearby lake.

Radiological impacts are minimized through adherence to Off-Site Dose Calculation Manual (ODCM) [13] limits and assessed through the REMP and the Radiological Groundwater

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-16 Protection Program (RGPP). Potential groundwater impacts are monitored by the routine sampling of 23 permanent on-site RGPP wells and other ground water locations at FCS.

As the water from the Missouri River is no longer used to cool operating reactor systems at FCS, the thermal impact to the Missouri River has been reduced.

No adverse impacts on surface water and groundwater are expected from the implementation of decommissioning activities. Consequently, the potential impacts to surface and groundwater quality are bounded by the GEIS and considered Small.

8.6.3.5 Air Quality The environmental impact evaluation associated with air quality in section 4.3.4 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

There are five non-radiological types of decommissioning activities listed in Section 4.3.4.3 of the GEIS that have the potential to affect air quality:

• worker transportation to and from the site

• dismantling of systems and removal of equipment

• movement of open storage of materials on-site

• demolition of buildings and structures

• shipment of material and debris to off-site locations 8.6.3.5.1 Worker Transportation The work force at FCS has decreased significantly from the time the plant ceased operation in 2016 to a work force of approximately 300 people. The work force will temporarily increase during decommissioning by approximately 150 people. There will also be occasional increases during specific D&D activities until completion. The work force during decommissioning will be smaller than the work force needed during plant construction and routine refueling/maintenance operations. Therefore, there will be no significant adverse changes in air quality associated with changes in worker transportation since these changes in worker transportation will generally not be detectable or destabilizing.

8.6.3.5.2 Dismantling Systems and Removal of Equipment There are potential sources of particulate matter that could impact air quality during the dismantlement of systems and the associated release of gases from systems during removal.

Several mitigation efforts can be used to minimize fugitive dust such as wet suppression and chemical stabilization agents. In addition, airborne contamination can be minimized by isolating certain contaminated areas and implementing the use of air filtration systems when activities are located in areas that are not ventilated to the plant stack and are likely to generate airborne radioactivity or other hazardous pollutants. Other sources of air pollutants such as refrigerants will be disposed of according to applicable local, state, and federal regulations. FCS complies with all applicable federal and state air quality regulations, including the requirements of the

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-17 NDEQ, and will implement the BMPs to minimize particulate matter generated during decommissioning and the released to the environment detectable off-site.

8.6.3.5.3 Movement and Open Storage of Materials On-Site Movement of equipment and open storage of materials such as construction debris and soil stockpiling during decommissioning may result in fugitive dust. However, BMPs such as temporarily stabilizing stockpiled soil with seed and mulch and spraying of the debris containing particulates and dust will minimize fugitive dust during stockpiling. Similar BMPs will be established to mitigate effects while moving material within the site. Therefore, no significant adverse impacts to air quality from the particulate matter generated as a result of movement or storage of material onsite are anticipated.

8.6.3.5.4 Demolition of Buildings or Structures It is anticipated that the demolition of buildings and structures will temporarily increase fugitive dust at FCS during decommissioning. Demolition activities will be conducted in an organized and methodical manner to avoid and minimize significant amounts of particulate and fugitive dust generation at one time during decommissioning. As demolition and loading of material occurs, the area exposed will be sprayed to minimize airborne dust and particulates. It is therefore anticipated that the demolition of buildings and structures will potentially create temporary impacts to air quality, but none that would be considered significant or adverse.

8.6.3.5.5 Shipments of Material to an Off-Site Location It is anticipated that truck traffic will be required to remove construction materials, debris, and equipment from the FCS. The removal of materials will take place during active decommissioning, and will be include varying periods of heavier and lighter activity. An average of eight trucks per day is estimated over the course of active decommissioning. This increase in total truck traffic when added to the Nebraska Department of Transportation average of 585 heavy vehicles per day from 2018, is lower than the truck traffic recorded while FCS was in service of 640 heavy vehicles per day [14].

Fugitive dust and small particulates generated from truck traffic will be the primary contributor of potential air quality impacts during this phase of decommissioning. All appropriate BMPs will be implemented and maintained throughout decommissioning to ensure that there is a minimal amount of impacts to air quality.

In addition to the current air monitoring program at FCS, all air emissions will be monitored during decommissioning activities (fugitive dust, equipment exhaust, etc.) and will continue to be monitored in accordance with the ODCM, which sets limits on doses caused by effluents, based upon the ALARA objectives of 10 CFR 50.34a, 10 CFR 50.36a, and Section IV.B.1 of Appendix I to 10 CFR 50. Effluents are reported annually to the NRC.

FCS complies with all applicable federal and state air quality regulations, including the requirements of the NDEQ, and will implement BMPs to minimize fugitive dust during demolition and decommissioning activities.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-18 No adverse impacts on air quality are expected from the implementation of decommissioning activities. Consequently, the potential impacts to air quality are bounded by the GEIS and considered Small.

8.6.3.6 Aquatic Ecology The environmental impact evaluation associated with aquatic ecology in section 4.3.5 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

The aquatic habitat at FCS includes the area in front of the intake structure integral to the Missouri River bank. Habitats associated with this area were previously disturbed during the initial construction of the facility. However, the implementation of decommissioning activities is not expected to disturb existing aquatic habitats, the flora and fauna of nearby streams and wetlands. The maintenance of the riverbank will allow the river and local aquatic habitats to be maintained.

Various fresh water fish species, macro-invertebrate populations, and vegetation exist within these aquatic environments and were identified during a study contracted by OPPD. OPPD performed a project decision model to assist with the decision for removing or leaving the Intake Structure and Circulating Water Discharge Tunnel at FCS. The project decision model concluded that the removal of the above ground structures and filling of the Lower Intake Structure and Circulating Water Discharge Tunnel should be completed. This decision resulted in the least impact to the environment, including aquatic ecology considerations.

Plans for the demolition of structures at FCS do not include the removal of waste or equipment by barge. Consequently, there is no impact to the riverbank from this type of activity.

OPPD will continue to maintain its NPDES permits and decommissioning operations will be performed within applicable NPDES limits. Furthermore, protection of the onsite and adjacent wetlands is, and will continue to be, a priority when planning any onsite dismantlement or waste management operation. In addition, the BMPs are implemented to prevent impacts to the aquatic systems.

Exotic species can threaten native species and ecosystems due to aggressive growth, reproduction or survival rate, and diseases or parasites they may transmit to native species. The decommissioning of FCS will not introduce any exotic plants or animals into the environment.

The potential impacts to the aquatic ecology within the site boundary are bounded by the GEIS and considered to be Small. The potential impacts to the aquatic ecology beyond the site boundary have also been evaluated and considered to be Small.

8.6.3.7 Terrestrial Ecology The environmental impact evaluation associated with terrestrial ecology in section 4.3.6 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

Direct impacts can result from activities such as clearing native vegetation or filling a wetland.

OPPD anticipates minimal disturbance of habitat beyond the operational areas of the plant. All

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-19 dismantlement, demolition, and waste staging activities are envisioned to be conducted within the operational area of the site. In addition, the NDEQ controls significant impacts to the environment through regulation of construction activities.

Indirect impacts may result from effects such as erosional runoff, dust, or noise. Any construction activities that would disturb one acre or greater of soil requires a storm water permit from the NDEQ prior to proceeding with the activity. The storm water permit contains BMPs to control sediment and the effects of erosion associated with the construction activity. Fugitive dust emissions will be controlled through the judicial use of water spraying.

Section 4.3.6 of the GEIS concludes that if BMPs are used to control indirect disturbances and habitat disturbance is limited to operational areas, the potential impacts to terrestrial ecology are Small. As discussed above, there are no unique disturbances to the terrestrial ecology anticipated during the decommissioning of FCS. Currently, FCS will be able to conduct all of these decommissioning activities on previously disturbed land. As required, the environmental impact will be reevaluated when activity is planned on previously undisturbed land. Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on terrestrial ecology are bounded by the GEIS.

8.6.3.8 Threatened or Endangered Species The threatened and endangered species are identified in the 2002 Environmental Report. In October 2018, a review for plant and wildlife species protected by the Nebraska Nongame and Endangered Species Act was requested by the Nebraska Game and Parks Commission. The conclusion of the reports indicate the terrestrial species that may be at or near the FCS include the following:

• three bird species: the federal and state threatened bald eagle (Haliaeetus leucocephalus) and piping plover (Charadnus melodus), the federal and state endangered least tern (Sterna antillarum)

• one reptile species: the state threatened massasauga rattle snake (Sistrurus catenatus)

• three plant species: the federal and state threatened western prairie fringed orchid (Plantanthera praeclara), the state threatened small white ladys-slipper (Cypripedium candidum) and American ginseng (Panax quinquefolium)

• three fish species: the federal and state endangered pallid sturgeon (Scaphirhynhcus albus), the state threatened lake sturgeon (Acipenser fulvescens) and sturgeon chub (Macrhybopsis gelida)

• The only new species that may be at or near FCS not listed in 2002 was identified in 2018. It was a mammal species: the federal and state threatened northern long-eared bat (Myotis septentrionalis).

Least terns and piping plovers nest on riverine sandbars within the central United States, including those present along the Missouri River. The loss of sandbar nesting habitat due to river channelization and changes in flow from the construction and operation of main-stem dams have resulted in population declines for both the least tern and the piping plover along the Missouri River.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-20 The amount of cooling water withdrawn from the Missouri River will significantly decrease, thus reducing the potential impacts of impingement, entrainment, and thermal discharges on aquatic species. One potential adverse impact from the decrease in cooling water withdrawn may be the elimination of the thermal refuge for aquatic species in the discharge area, which are preyed upon by the bald eagle in the winter months. Removal of the intake and discharge facilities as well as other shoreline structures will be conducted in accordance with BMPs outlined in permits issued by the NDEQ and the U.S. Army Corps of Engineers.

The historic range of the massasauga included eastern Nebraska and Washington County, but there are no recent records within 50 miles of FCS. Extant populations of the massasauga have been documented only in Colfax and Pawnee counties. This small rattlesnake prefers wet prairie habitat.

Two plant species are listed by the State of Nebraska, but not by the Federal Government. These include small white lady's-slipper (Nebraska-listed as threatened; occurs in wet meadows) and American ginseng (Nebraska-listed as threatened; occurs in high quality upland forest). The listed species are not known to occur on FCS.

The western prairie fringed orchid (federally listed as threatened) is found most often on unplowed, calcareous prairies and sedge meadows. It potentially occurs in Washington County, based on historic observations, but no populations are known to occur in the county, and the potential for occurrence on or near FCS is low given the lack of prairie habitat in these areas.

No designated critical habitat exists for any of the listed aquatic species on or in the vicinity of FCS. No aquatic species in the area is proposed for listing or is a candidate for listing. The FCS site is located within a reach of the Missouri River that has been channelized, with a relatively uniform width and swift current. This channel degradation results in a reduction of sediment and organic matter, flow modifications, and channel narrowing. As a result, it is believed that the cues for spawning are no longer present.

OPPD environmental personnel conduct monthly site environmental inspections to monitor for adverse environmental impacts and general environmental conditions including protected species. OPPD also has a plan in place for protection of the bats, as well as other mammals and birds that may be encountered in their service territory.

The environmental impacts during decommissioning are expected to be minimal on threatened and endangered terrestrial species. Additionally, FCS has administrative controls in place which require that significant project activities undergo an environmental review prior to the activity occurring, which ensures that impacts are minimized through implementation of BMPs and the OPPD Avian Protection Plan [15]. State permits are required, which include evaluation of the impacts to the environment and considerations of threatened and endangered species that may occur from the specific activity. Any necessary mitigation activities, should any be identified due to environmental consequences at the time, would receive the appropriate state permitting. This process also includes federal triggers to check for federal threatened and endangered species. No demolition at FCS would be allowed to proceed without the appropriate approval. Based on the above, the planned decommissioning of FCS will not result in a direct mortality or otherwise jeopardize the local population of any threatened or endangered species.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-21 The potential impacts to Threatened or Endangered species are bounded by the GEIS and considered Small.

8.6.3.9 Occupational Issues/Safety The environmental impact evaluation associated with occupational issues in Section 4.3.10 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact. While decommissioning involves increased industrial activities and safety focus, similar programs addressing worker safety were implemented during the operation of the facility and also during repair and refueling outages. The occupational issues and safety impacts assessed are those related to human health and safety, including impacts from physical, chemical, ergonomic, and biological hazards. Radiological impacts were previously discussed in Section 8.6.2.1.

OPPD and EnergySolutions are committed to decommissioning FCS safely, and OPPD has established the HASP to effectively control hazards in the work environment and prevent occupational injuries and illnesses. The HASP and OPPD/EnergySolutions comply with federal and state regulations including Nebraska Department of Labor and the U.S. Occupational Health and Safety Administration requirements. The HASP applies to all OPPD and EnergySolutions employees as well as visitors and contract personnel working under direct OPPD or EnergySolutions supervision.

Numerous safety practices and communications are conducted at the site and include, but are not limited to:

• Safety is emphasized as the first topic of discussion at meetings.

• All workers are provided a Health and Safety booklet.

• Worker training and required certifications are reviewed prior to assignment to tasks requiring specific worker qualifications. Certain specialty subcontractors are mobilized, as necessary.

• Safety Data Sheets are obtained and reviewed for chemicals brought on-site.

• Health and Safety staff are involved in reviewing and approving decommissioning work packages and participating in pre-job walk downs, work condition assessments, and reviews.

• Daily and weekly safety messages are issued as well as Safety Bulletins to communicate awareness of significant safety issues and lessons learned.

• Safety stand-downs are held whenever serious safety events occur to communicate and reinforce safety events and lessons learned site-wide.

Therefore, occupational issues/safety is evaluated to be bounded by the GEIS, and the impact is considered Small.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-22 8.6.3.10 Cost A detailed discussion of the site decommissioning project costs is presented in Chapter 7 of this LTP.

8.6.3.11 Socioeconomic Impacts OPPDs original decision to permanently cease plant operations was not subject to NRC review or approval. On June 16, 2016, the OPPD Board of Directors voted to permanently cease operations of FCS for financial reasons.

As FCS transitions from shutdown and into the different phases of decommissioning, an overall decrease in plant staff will occur. The lost wages of these plant staff may result in decreases in revenues available to support the local economy.

Although FCS may have some effect on the region as a whole, the vast majority of FCS employees have resided in Washington, Douglas, and Sarpy Counties. FCS employees may be expected to impact the economy the most in terms of real estate and consumer goods within the counties where they live. Therefore, any effects of FCSs closure are expected to be focused within these counties. Although effects outside of the counties are possible, if the effects within these counties are negligible, it is expected that effects in the surrounding areas are also negligible. Therefore, FCS closure should not have a significant adverse impact on the local economy in the years following closure.

Therefore, socioeconomic impacts are evaluated to be bounded by the GEIS, and the impact is considered Small.

8.6.3.12 Environmental Justice While low-income and minority populations are present in the vicinity of the former FCS, the percentages of low-income and minorities within the FCS census tract are lower than those in other surrounding county census tracts. No disproportionate impact to the greater population, including special groups, is expected.

An existing rail spur was modified to transport large components and other waste from FCS. The refurbished rail spur is used to transport waste over an existing route. Decommissioning activities will cause increases in truck traffic to and from FCS to transport equipment and debris.

The truck traffic will use existing highway and main street routes. Since a majority of the waste will be removed by rail, the increase in truck traffic will be temporary. There will be no environmental justice impact relative to rail and truck transportation as a result of decommissioning.

Based on the radiological environmental monitoring program data from FCS, the Supplemental Environmental Impact Statement (SEIS) determined that the radiation and radioactivity in the environmental media monitored around the plant have been well within applicable regulatory limits. As a result, the SEIS found that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations (i.e., minority and/or low-income populations) in the region as a result of subsistence consumption of water, local food, fish, and wildlife.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-23 There is no reason to believe that low-income and minority populations will be adversely impacted by the decommissioning project. Per the GEIS and this evaluation, the potential site-specific impact is considered Small.

8.6.3.13 Cultural, Historic, and Archaeological Resources Based on a review of the FCS property through the Nebraska State Historic Preservation Office (NSHPO) files and information provided by the applicant, the NRC concluded in Section 4.4.5 of the SEIS that the potential impacts from decommissioning of FCS on historic and archaeological resources would be Small.

FCS has an existing rail spur that was modified to ship waste and large components off-site.

Land disturbance for the removal of large components is minimized, because removal is primarily conducted via the site rail system.

A section of the plant site that lies north of the rail spur and is bounded on the southwest by U.S.

Highway 75 was determined as having Moderate to High Potential. It contains remnants of the former town of Desoto, Nebraska. Based on the impacts of past construction activities, the plant site being situated on floodplain alluvium, and having been developed since 1850, and the section of the site that lies south of the current Union Pacific rail spur should be categorized as having no potential for cultural resources, either prehistoric or historic.

Environmental review procedures have been put in place at FCS regarding undertakings that involve land disturbing activities in undisturbed surface and subsurface areas. These environmental protection procedures include contacting the NSHPO to establish the actions necessary to protect known or as of yet undiscovered cultural resources before an action is allowed to occur. The cultural, historic, and archaeological impact evaluation conducted in the GEIS focused on similar attributes as the SEIS. The GEIS evaluated direct effects such as land clearing and indirect effects such as erosion and siltation.

The conclusion for the license renewal evaluation is also applicable to the decommissioning period, because:

• decommissioning activities will be primarily contained to disturbed areas located away from areas of existing or high potential for archaeological sites,

• construction activities that disturb one acre or greater of soil are permitted by NDEQ approval, and BMPs are required to control sediment and the effects of erosion, and

• environmental protection procedures pertaining to archaeological and cultural resources will remain in effect during decommissioning.

Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on cultural, historic, and archaeological resources are Small and are bounded by the GEIS. Based on the historical information in the AEC Environmental Statement, the results of the reviews of historic, cultural, and archaeological resources performed in 2013 and 2014, current transportation methods for large components, and soil erosion control work practices, the decommissioning will have no significant impact on cultural and historic resources.

Archaeological resources would be Small.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-24 8.6.3.14 Aesthetics The environmental impact evaluation associated with aesthetics in Section 4.3.15 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

The impact of decommissioning on site aesthetics (e.g., visual skyline) is limited in terms of land disturbance and duration. These impacts are temporary and will cease when decommissioning is completed.

The location of the ISFSI is set back several hundred yards from the river frontage and located near the existing switchyard. Once all of the major plant structures and buildings on the riverbank are removed, aesthetics will improve by providing a more open view of the Missouri River. Restoration of the site to a more natural grade will result in a contiguous open view of the Missouri River.

Aesthetics will improve once the site is returned to open space. Therefore, the environmental impact associated with aesthetics is evaluated to be bounded by the GEIS, and the impact is considered Small.

8.6.3.15 Noise The environmental impact evaluation associated with noise in Section 4.3.16 of NUREG-0586, Supplement 1 has been determined to be generally applicable to FCS with a Small impact.

FCS is located on the riverbank of the Missouri River. There are no residences within one half mile of the station, and no schools, hospitals, prison, motels, or hotels are in the immediate vicinity of the site. The center of the nearest community, Blair, Nebraska, is located approximately three miles to the northwest of the site.

Noise generation will primarily result from demolition activities involving heavy construction equipment. The noise from the shipment of waste will be minimal since the primary transportation method for shipment of LLRW will be by rail. Noise associated with decommissioning and shipment of waste is intermittent and temporary.

The ISFSI construction was completed in 2005. The ISFSI is a passive facility and there will be minimal noise generated from its operation. Once the decommissioning is complete, noise levels in the vicinity of the FCS site will be reduced to levels below those experienced during the operation of the facility.

Due to the distance of the station from sensitive receptors, there will be limited temporary impacts on noise levels during decommissioning and demolition activities. Therefore, the environmental impact associated with noise is evaluated to be bounded by the GEIS, and the impact is considered Small.

8.6.3.16 Irretrievable Resources During the demolition and structural dismantlement of the station, recycling and asset recovery efforts will be made. Some metals (e.g., from turbine, transformer components, etc.) have been released as clean scrap.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-25 Uranium is a natural resource that is irretrievably consumed during power operation. After the plant is shutdown, uranium is no longer consumed. The use of the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment, but rather a relatively short-term investment. Since the FCS site will be decommissioned to meet the unrestricted release criteria found in 10 CFR 20.1402, the land is not considered an irreversible resource. LLRW has been, and will continue to be, shipped to the EnergySolutions disposal site in Clive, Utah. This facility has sufficient space for the disposal of this waste. In addition, Class B/C waste that is generated may also be shipped to the Waste Control Specialists facility in Andrews, Texas.

As stated in the GEIS, irretrievable resources that would occur during the decommissioning process are the materials used to decontaminate the facility (e.g., rags, solvents, gases, and tools) and fuel used for construction machinery and for transportation of materials to and from the site.

These resource commitments are considered to be minor and are neither detectable nor destabilizing. Therefore, the environmental impact associated with irretrievable resources is evaluated to be bounded by the GEIS, and the impact is considered Small.

8.6.3.17 Traffic and Transportation The number of shipments and the volume of waste shipped are greater during decommissioning than during the operation of the facility. Non-radiological impacts of transportation include increased traffic and wear and tear on roadways. Because the majority of the waste will be transported by rail, the average number of daily shipments from the site will be relatively small.

Consequently, it is anticipated that there will be no significant effect on traffic flow or road wear.

The impacts of a transportation accident would be neither detectable nor destabilizing. Therefore, the environmental impact associated with traffic, transportation is evaluated to be bounded by the GEIS, and the impact is considered as Small.

8.6.3.18 Placement of Clean Concrete Demolition Debris and Sand Mix in Major Building Basements: Terrestrial Ecology and Transportation OPPD evaluated the use of clean concrete demolition debris for basement fill end state, and subsequently determined only clean fill is to be used.

8.7 Overview of Regulatory Governing Decommissioning Activities and Site Release 8.7.1 Federal Requirements Decommissioning activities that are subject to federal regulations include:

• spent fuel and GTCC storage at the ISFSI

• handling, packaging, and shipment of radioactive waste

• worker radiation protection

• license termination and final site release

• worker health and safety

• liquid effluent releases

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-26

• hazardous waste generation/disposition

• handling and removal of asbestos

• characterization and removal of polychlorinated biphenyls (PCBs)

• handling and removal of lead paint 8.7.1.1 NRC The majority of radiological activities falls under Title 10 of the Code of Federal Regulations and are administered by the NRC. Applicable Title 10 regulations include:

• Part 20 - Radiation protection

• Part 50 - Decommissioning activities

• Part 51 - Environmental protection

• Part 61 - Disposal of radioactive waste

• Part 71 - Packaging and transportation of radioactive waste (regulations in 49 CFR Parts 171 through 174 also apply)

• Part 72 - Licensing requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, and reactor-related GTCC waste

• Part 73 - Physical protection of plants and materials 8.7.1.2 EPA The EPA regulations outlined in Title 40 of the Code of Federal Regulations apply as follows:

• Part 61 - Asbestos handling and removal

• Parts 122 to 125 - NPDES

• Part 141 - Safe drinking water standards

• Part 190 - Radiation protection standards for nuclear power operations

• Parts 260 to 272 - Resource Conservation and Recovery Act

• Part 280 - Underground storage tanks

• Part 761 - Toxic Substance Control Act for PCBs

• Part 129-132 - Clean Water Act 8.7.2 State and Local Requirements Permits and approvals from or notifications to state and local agencies are required for safety and environmental protection purposes. Decommissioning activities and related site operations that fall under State and local jurisdiction include, but are not limited to, the following:

• Nebraska Department of Environmental Quality

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-27

• Nebraska Department Health and Human Services

• Nebraska State Historical Society This information provided above is a general overview of the applicable regulations and not intended to be all-inclusive.

8.8 Conclusion As previously evaluated in the FCS PSDAR, the non-radiological environmental impacts from decommissioning FCS are temporary and not significant. The potential issues identified as site-specific in NUREG-0586, Supplement 1 (such as Threatened and Endangered species and environmental justice) have been evaluated, and there is no significant impact. The potential environmental impacts associated with decommissioning FCS have already been predicted in and will be bounded by the previously issued environmental impact statements (PSDAR, NUREG-0586, and FCS Environmental Statement). Therefore, there are no new or significant environmental changes associated with decommissioning.

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-28 8.9 References

[1] U.S. Nuclear Regulatory Commission, "Regulatory Guide 1.179, Revision 2, Standard Format and Contents for License Termination Plans for Nuclear Power Reactors, 2019.

[2] Updated Environmental Report Fort Calhoun Station File No. 127690-003" (LIC-20-0013, ML20202A654), March 2019.

[3] U.S. Atomic Energy Commission, Final Environmental Statement related to operation of Fort Calhoun Station Unit 1 (WIP 031037), March 1971.

[4] U.S. Nuclear Regulatory Commission, "NUREG-1437, Supplement 12, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Fort Calhoun Station Unit 1 - Final Report, 2003.

[5] Omaha Public Power District, Fort Calhoun Station Unit 1, Post Shutdown Decommissioning Activity Report.

[6] U.S. Nuclear Regulatory Commission, "NUREG-0586, Supplement 1, Volume 1, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, 2002.

[7] Correspondence, Olsson Engineering to the Army Corps of Engineers, February 2021.

[8] U.S. Nuclear Regulatory Commission, "NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities, 1997.

[9] U.S. Census Bureau American Community Survey report - 2010.

[10] Radiation Safety and Control Services, "TSD 20-001, Historical Site Assessment for Fort Calhoun Station, 2020.

[11] National Centers for Environmental Information, National Oceanic and Atmospheric Administration, www.ncdc.noaa.gov/stormevents/.

[12] Omaha Public Power District, "FCS-SAF-103, FCS Deconstruction Health and Safety Plan.

[13] Omaha Public Power District, "CH-ODCM-0001, Offsite Dose Calculation Manual.

[14] Nebraska Department of Transportation, gis.ne.gov/portal/apps/webappviewer/index.html?id=bb00781d6653474d945d51f49e1e7c34.

[15] Omaha Public Power District, "Avian Protection Plan".

FORT CALHOUN STATION DECOMMISSIONING PROJECT LICENSE TERMINATION PLAN REVISION 2 8-29 Table 8-1 Summary of the Environmental Impacts from Decommissioning Section Environmental Issue GEIS Impact Onsite/Offsite Land Use 8.6.3.1

- Onsite Land Use Yes SMALL 8.6.3.2

- Offsite Land Use No Site Specific 8.6.3.3 Water Use Yes SMALL 8.6.3.4 Water Quality Surface Water Yes SMALL Ground Water Yes SMALL 8.6.3.5 Air Quality Yes SMALL 8.6.3.6 Aquadic Ecology Activities Within the Operational Area Yes SMALL Activities Beyond the Operational Area No Site Specific 8.6.3.7 Terrestrial Ecology Activities Within the Operational Area Yes SMALL Activities Beyond the Operational Area No Site Specific 8.6.3.8 Threatened and Endangered Species No Site Specific 8.6.2 Radiological Activities Resulting in Occupational Dose to Workers Yes SMALL Activiteis Resulting in Dose to the Public Yes SMALL Radiological Accidents Yes SMALL 8.6.3.9 Occupational Issues Yes SMALL 8.6.3.10 Cost*

N/A N/A 8.6.3.11 Socioeconomics Yes SMALL 8.6.3.12 Environmental Justice No Site Specific 8.6.3.13 Cultural and Historic Impacts Activities Within the Operational Areas Yes SMALL Activities Beyond the Operational Area No Site Specific 8.6.3.14 Astethics Yes SMALL 8.6.3.15 Noise Yes SMALL 8.6.3.17 Transportation Yes SMALL 8.6.3.16 Irretrevable Resources Yes SMALL 8.6.3.18 Placement of Clean Debris No Site Specific Note: Cost, Section 4.3.11 in GEIS Supplement 1, is not evaluated using environmental significance levels and is not identified as a generic or site-specific issue.