ML25083A225
| ML25083A225 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/24/2025 |
| From: | Omaha Public Power District |
| To: | Division of Decommissioning, Uranium Recovery and Waste Programs |
| References | |
| EPID L-2024-LLA-0095 | |
| Download: ML25083A225 (1) | |
Text
Attachment 1 Response to NRC Request for Additional Information Fort Calhoun Station Revision 2 to the License Termination Plan Question on Environmental Review 4 Pages to Follow
Page 1 of 4 NRC Request for Additional Information:
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.
Page 2 of 4 OPPD Response:
Potential Impacts to Several Proposed Species There has been a request to analyze the potential presence and impacts to three proposed threatened or endangered species at Fort Calhoun Station (FCS). OPPDs Wildlife and Natural Resources Program Manager read the proposed listings in the federal register for each of the following species and analyzed any possible impacts at FCS.
Monarch Butterfly The monarch butterfly (Danaus plexippus) is found across Nebraska and will be present on the FCS site throughout the summer. US Fish and Wildlife Service (USFWS) proposed to list the monarch butterfly as a threatened species with protective regulations under section 4(d) of the Endangered Species Act (ESA) on December 12, 2024. There are several exceptions for minimal levels of take built into the provisions of the proposed 4(d) rule and several activities that do not result in conversion of native or naturalized grassland, shrubland, or forested habitat will not be prohibited.
One activity is related to habitat restoration and management activities that will take place at the FCS prairie. Future work on the prairie will include tree removal, spraying of invasive plants, mowing, and additional wildflower seeding. All these activities will benefit the monarch butterfly by improving the health and diversity of flowering plants (nectar sources) and milkweed for reproduction. Other activities are routine agricultural practices on the existing farm ground. These activities will include the planting and harvesting of corn and beans, cutting and baling of alfalfa, and mowing along the perimeter of the field and roads.
The farm tenant may also assist in the planting and management of new prairie on areas not fit to farm. The proposed 4(d) rule also includes exception for any take from vehicle strikes because currently, the impact of monarch deaths due to vehicle strikes are considered minimal. Vegetation management activities such as mowing and ground disturbance that removes milkweed and/or nectar plants when monarch is not likely present would also be allowed under the proposed 4(d) rule.
The largest amount of work on the property will be centered around the removal of structures, filling these areas with soil, and grading. These activities will have minimal impact on monarchs because monarch habitat is not located where this work is taking place. Over the entire area, the removal of the structures, farming, vegetation management, and use of vehicles will have a minimal/if any effect on the monarch butterfly. Work on the existing prairie and establishment of any new prairie at FCS, could have a positive effect on breeding monarch butterflies. As of now, no critical habitat has been designated in Nebraska.
Suckleys Cuckoo Bumble Bee USFWS proposed to list the Suckleys cuckoo bumble bee (Bombus suckleyi) as an endangered species under the ESA on December 17, 2024. The Suckleys cuckoo bumble bee is an obligate social parasite and cannot reproduce without a social host colony. They lack the mechanism to carry pollen to feed their young and must lay their eggs in a suitable bumble bee colony nest to be raised by the hosts. The small prairie at FCS has flowering plants from spring through fall that severe as a nectar source for pollinators. OPPDs Wildlife and Natural Resources Program Manager walked the prairie twice during the
Page 3 of 4 summer of 2024 to identify flowering plants and did not opportunistically encounter any ground-nesting bumble bee nests.
The Suckleys bumble bee has two confirmed hosts, both have no known records in the Omaha Public Power District (OPPD) service territory according to A Guide to the Bumble Bees of Nebraska created by the Xerces Society for Invertebrate Conservation in collaboration with University of Nebraska-Lincoln. One host is the western bumble bee (Bombus occidentalis) whose range includes the mountainous region of North American extending into western Nebraska. The other is the Nevada bumble bee (Bombus nevadensis) whose range does include Nebraska but is mainly found in western Nebraska.
There are seven known records of a Suckleys cuckoo bumble bee in Nebraska: three in Lancaster County (1892,1999, 2000), one in Saunders County (1999), and three in Sioux County (all in 2000). This species has not been found in the United States since 2016 despite increased sampling efforts across the country. In Nebraska, an effort called The Bumble Bee Atlas started in 2019 and has completed nearly 1,300 surveys and recorded over 10,000 sightings of bumble bees from 2019 - 2024. The chance of finding this bumble bee on the FCS property would be highly unlikely. As of now, the determination of critical habitat for this species is not determinable.
Western Regal Fritillary The western regal fritillary (Argynnis idalia occidentalis) requires large tracts of intact non-degraded prairie, 100s of acres. An established population is unlikely to be found in an altered landscapes such as row crop and non-native pasture surrounding prairie remnants.
USFWS proposed to list the western regal fritillary as a threatened species with protective regulations under section 4(d) of the ESA on August 06, 2024. There is a chance this butterfly could pass through the FCS site, but there are less than 10 acres of prairie at the front entrance. This small prairie has a variety of flowering plants throughout the summer, but the surrounding area is heavily wooded with most open areas used for agriculture or covered in cool season grasses. This area could serve as a nectar source for butterflies passing through the area but would likely be too small to support a reproducing population of the western regal fritillary. On such a small prairie, only one adverse event could extirpate the entire population. It would also be unlikely that new regal fritillary butterflies would successfully move into the area and reestablish a population because of the fragmented habitat surrounding FCS. The regal fritillary is dependent on violets, as this is the only food source for their larva. Violets were not opportunistically observed by OPPDs Wildlife and Natural Resources Program Manager during two prairie transect walks while conducting a flowing plant inventory in 2024, but they may exist.
There are several exceptions for minimal levels of take built into the provisions of the proposed 4(d) rule and these activities include noxious weed control, haying and mowing, and brush control. Any management activities to the FCS prairie will not remove the thick layer of thatch present that is needed for reproduction if regal fritillary is in the area. Any herbicide uses in or near the prairie will be used selectively to control invasive species or tree encroachment.
Some large projects on the property are centered around the removal of structures, moving a large pile of dirt to fill in holes created from removing these structures, and returning those areas to grade. Another large project across the FCS property is agricultural that
Page 4 of 4 include the growing and harvesting of crops, the cutting and baling of alfalfa, and mowing of grass and weeds along the perimeter of the fields. These areas have been continually disturbed through the years and contain very few flowering plants or built-up thatch. These activities will have minimal impact on the regal fritillary because their habitat is not located where this work is taking place. It is highly unlikely that any activities on FCS will have a negative effect on the regal fritillary. As of now, the determination of critical habitat for the western regal fritillary is not determinable.