ML25071A146

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Question on Environmental Review of Request to Approve Rev 2 of the FCS LTP
ML25071A146
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 03/11/2025
From:
Office of Nuclear Material Safety and Safeguards
To:
References
EPID L-2024-LLA-0095
Download: ML25071A146 (1)


Text

1 Question on Environmental Review for request to approve Revision 2 of the Fort Calhoun LTP Discussion: The Combined TR/ER does not analyze the potential impacts to several proposed threatened or endangered species that may occur in the action area. These include:

Monarch butterfly (Danaus plexippus) (federally proposed threatened)

Western regal fritillary (Argynnis idalia occidentalis) (federally proposed threatened)

Suckleys Cuckoo bumble bee (Bombus suckleyi) (federally proposed endangered)

The Western Regal Fritillary was proposed threatened on August 6, 2024 (89 FR 63888), the Monarch Butterfly was proposed threatened on December 12, 2024 (89 FR 100662), and the Suckleys Cuckoo Bumble Bee was proposed endangered on December 17, 2024 (89 FR 102074).

The three species were not listed or proposed for listing during the previous environmental review of the LTP (ML23333A049) and therefore an effects determination needs to be made for all three species for the full site decommissioning pursuant to the Endangered Species Act (ESA). Under ESA, the proposed license amendment and the full LTP and site decommissioning are the same federal action and all potential effects to ESA protected species must be considered prior to the NRC issuing any licensing decision.

The Monarch Butterfly was included in the initial LTP EA but was not a proposed species at the time. Please confirm all information pertaining to the monarch butterfly in the current version of the supplemental environmental report (ER) is accurate and up to date (ML25016A212). For the western regal fritillary and suckleys cuckoo bumble bee, please provide information about any locations at the site that fit the description of their respective habitats and well as any potential impacts to the habitat from site decommissioning activities. The impacts considerations do not need to consider previously completed decommissioning work, only current, ongoing, or future actions involving the site.

RAI: Please provide information concerning the presence of each of these species and suitable habitat within the action area, including information on any observations of species, and local population abundances. Provide copies of any recent ecological surveys or monitoring conducted at the site involving these species. Provide an analysis of the impacts of the proposed action on the species listed above. Specifically, for each species, include the following information.

1. Monarch butterfly: The analysis for this species should address (1) mortality or injury from collisions with structures and vehicles; (2)habitat loss, degradation, disturbance, or fragmentation, and associated effects; (3) insecticide and herbicide usage and application, and (4) behavioral changes resulting from site activities, among other impacts relevant to this species that the applicant may identify
2. Western regal fritillary: same as monarch.
3. Suckleys Cuckoo bumble bee: same as monarch.

2 Basis: As required by 10 CFR 51.45 and 10 CFR 51.60(a)(b), applicants shall assess the impact of the proposed action on the environment, including threatened or endangered species. This analysis is also required in accordance with Federal laws protecting wildlife, including but not limited to, the Endangered Species Act (ESA). The ESA regulations at 10 CFR 402 require Federal agencies to confer with the U.S. Fish and Wildlife service (FWS) concerning Federally listed species and species proposed for Federal listing under ESA Section 7.