ML25356A369
| ML25356A369 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos File:GEH Hitachi icon.png |
| Issue date: | 01/07/2026 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| Download: ML25356A369 (7) | |
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DRAFT FOR PUBLIC REVIEW AND COMMENT Vallecitos Nuclear Center License Amendment Request to Update Historic and Cultural Resources The following document is a draft version of the historic and cultural resources analysis for the Vallecitos Nuclear Center. The report will be included in the U.S. Nuclear Regulatory Commissions (NRC) final environmental evaluation.
Please review and provide comments by February 8, 2026.
Comments can be emailed to the following:
Beau Goldstein, Archaeologist, at Beau.Goldstein@nrc.gov Jill Caverly, Sr. Project Manager, at Jill.Caverly@nrc.gov For questions regarding this document, please reach out to either of the two NRC staff identified above either by email or phone. Beau Goldstein can be reached at 301-415-1765, and Jill Caverly can be reached at 301-415-7674.
1 1.1 Historic and Cultural Resources 1.1.1 Affected Environment The National Historic Preservation Act of 1966, as amended (NHPA), requires federal agencies to consider the effects of their undertakings on historic properties; the license termination and decommissioning activities at the Vallecitos Nuclear Center (VNC) are an undertaking that could potentially affect historic properties, should such properties be present. The NHPA defines historic properties as any prehistoric or historic district, site, building, structure, or object included in, or eligible for, inclusion in the National Register of Historic Places (NRHP). Historic properties are a subset of cultural resources that are considered during the National Environmental Policy Act (NEPA) process. Cultural resources include, but are not limited to, properties that may not be NRHP-eligible or listed; places or landscapes of traditional cultural importance; and sacred, ceremonial, and religious sites.
General Electric (GE) was issued license Construction Permit Power Reactor (CPPR)-3 to construct and operate the Vallecitos Boiling Water Reactor (VBWR) on May 14, 1956, as Domestic Production Reactor (DPR). License CX-2 to operate DPR was issued July 29, 1957, and initial criticality was achieved on August 3, 1957. License DPR-1 was issued to GE on August 31, 1957, and full power was attained on October 19, 1957. The VBWR ceased operations on December 9, 1963, was defueled on December 24 of that same year, and GE was issued a license to possess but not operate the VBWR reactor on September 9, 1965. The Atomic Energy Commission (AEC), precursor to the NRC, issued GE an Order to Dismantle the VBWR on July 25, 1966. (GE Hitachi 2023, ML23305A191; as updated by NorthStar 2024a, ML24220A200).
GE constructed the General Electric Test Reactor (GETR) and its steel-domed containment building beginning in August 1957. The facility reached criticality in December 1958, receiving AEC Test Reactor License 1. In 1977, the discovery of a fault line near the VNC sparked concerns about the safety of the facility in a seismic event. By October, the NRC decided to shut down the GETR (SEARCH 2025). A possession only license was issued in February 1986 and renewed on Sep 30, 1992, with the GETR remaining in a storage condition known as SAFSTOR. The NRC staff has determined that the area of potential effects (APE) is the entire 1,600-acre VNC footprint (VNC shall refer to the entire 1,600-acre facility).
Decommissioning activities within the licensed site boundary and areas previously disturbed by the original construction would include the removal of above grade structures and some paved surfaces, decontaminating, and backfilling deep basements; select below grade structures will remain. There would be no disturbance to intact soil nor any tree clearing.
The NRC staff reviewed the current and historic land use within and immediately adjacent to the VNC site. In addition, the NRC staff relied upon historic and cultural resources descriptions provided in GE Hitachi 2023 (ML23305A191), NorthStar 2024a (ML24220A200), SEARCH 2023 (non-public), NorthStar 2024b (ML24270A224), and SEARCH 2025 (non-public) to inform their independent analysis.
An architectural inventory of the 200 and 300 series buildings was conducted by SEARCH 2023 (non-public), which recommended the VBWR and GETR individually eligible for listing on the NRHP under Criterion A (contribution to the advancement of nuclear technology) and Criterion C (significance in engineering); no other buildings or structures were recommended individually
2 NRHP-eligible. SEARCH 2023 (non-public) also recommended that the 200 and 300 series buildings were not eligible as a potential historic district. The NRC staff independently evaluated SEARCH 2023 (non-public) and determined that the VBWR and GETR were individually NRHP-eligible and made a finding of adverse effect; correspondence was sent to consulting parties of the NRC staffs determination and finding. Based on a response from the California State Historic Preservation Office (CA SHPO) requesting additional and clarifying information, and an expanded APE, additional data collection and evaluations were conducted. Consultations are described in Section 4.
The original architectural survey report (SEARCH 2023) identified an APE that was limited to the 200 and 300 complexes. However, based on consultation responses received, the NRC staff expanded the APE to include the entire VNC (approximately 1,600 acres), which includes complexes 100, 200, 300, and 400, and the Hillside Storage Area. An updated architectural survey was conducted by the licensee (SEARCH 2025) that includes a re-evaluation of the 200 and 300 complexes and an evaluation of the newly identified APE, discusses and summarizes previous identification and evaluation efforts, and provides updated recommendations of eligibility and effect.
The updated architectural survey (SEARCH 2025) recommended that no buildings, structures, or objects within the APE are individually NRHP-eligible, and that no buildings, structures, or objects contribute to the eligibility of a potential district. Specifically, as it pertains to the GETR and VBWR, the report states that the character defining features of each were the internal components, consisting of their form, fuel, and machined parts. SEARCH 2025 concluded that since the internal components were removed, the GETR and VBWR no longer retain sufficient integrity to convey their significance:
GETR:
o The previous report by SEARCH recommended GETR as eligible for listing in the NRHP under Criteria A and C. However, additional background research conducted for this project and further understanding of nuclear technologies indicates the resource lacks integrity. The resource is significant for its role as an early test reactor. Its character is defined by the fuel, machined parts, and the form that allowed for the tests. In order to put the reactor into SAFSTOR condition, many of these characteristics were removed or altered; as such, the resource lacks integrity of materials, design, and workmanship. Additionally, the reactor has diminished integrities of feeling and association. GETR is defined by its engineering and Although GETR is significant under Criterion A and C as an early test reactor, it no longer retains sufficient integrity to convey its significance. (SEARCH 2025:48; non-public)
VBWR:
o SEARCH previously recommended Building 301, VBWR, as eligible for listing in the NRHP. However, the building has since lost integrity of material, feeling, and workmanship, as well as has diminished integrities of feeling and association, as the reactor core was removed from the containment building in 2023. (SEARCH 2025:58; non-public) o Building 301, VBWRs now empty containment building, is significant for engineering that furthered nuclear technologies and research. The character
3 defining features of the resource was the reactor and its engineering, including its form, fuel, and machined parts that together allowed for the advancements of technology in boiling water reactors. Removal of the reactor core removed the components that made the building significant. Research indicates the containment building itself is not of significant engineering. SEARCH finds the resource no longer retains integrity of materials, design, or workmanship, and diminished integrities of association and feeling. As such, the resource lack[s]
sufficient integrity to convey its significance. As such, SEARCH recommends the resource is not eligible for individual for NRHP inclusion. (SEARCH 2025: 62 -
63; non-public)
During the lifespan of a reactor and containment building, normal operations include maintenance, removal, and replacement of fuel and facility/structure components, as well as alterations to facility/structure internals and externals. These activities are critical to provide reasonable assurance of adequate protection of public health and safety and protect the environment, key aspects of NRCs mission statement. As noted, a reactor and a containment building are subject to normal maintenance activities during their lifespan; therefore, feeling and association become the most significant aspects of its historical integrity. Due to security and safety measures at nuclear facilities, the general public would not be familiar with reactor and containment building internals or the ongoing updates, maintenance or changes within the building themselves. The public would be most familiar with the external appearance of such facilities.
As part of its review, the NRC staff referenced National Register Bulletin 15, How to Apply the National Register Criteria for Evaluation (National Park Service 1997) which states that a property that is significant for its historic association is eligible if it retains the essential physical features that made up its character or appearance during the period of its association with the historical pattern. National Register Bulletin 15also states that those essential physical features must be visible enough to convey their significance. Reactor/containment building internals are rarely, if ever, accessible to the public. Further, the bulletin states that for some historic buildings, their contribution to the built environment can be appreciated even if their interiors are not accessible. The NRC staff conclude that the GETR and VBWR maintain enough of the external physical features from their periods of significance to convey their association with their contribution to the advancement of nuclear technology.
The NRC staff conclude that no buildings, structures, or objects contribute to the eligibility of a potential district at the VNC. However, the NRC staff concludes that the GETR and VBWR retain sufficient integrity to convey their individual significance and has determined that they are NRHP-eligible under Criterion A (association with events that have made a significant contribution to the broad patterns of history) within the following contexts:
GETR - contribution to the advancement of nuclear technology and as the AECs first licensed test reactor; period of significance is 1958 - 1970 VBWR - contribution to the advancement of nuclear technologies and as the AECs first licensed power reactor; period of significance is 1957 - 1963
4 1.1.2 Impacts Decommissioning GEIS Determination As discussed in the Decommissioning Generic Environmental Impact Statement (GEIS; NRC 2002; ML023470304), in most cases, the amount of land required to support the decommissioning process is relatively small and is a small portion of the overall plant site.
Typically, the areas disturbed or used to support decommissioning are within the operational areas of the site and typically are within the protected area. For plants where the disturbance of lands beyond the operational areas is not anticipated, the impacts on cultural, historic, and archaeological resources are not considered to be detectable or destabilizing. The GEIS concluded the impacts of decommissioning on historic and cultural resources within the operational area are SMALL. The staff does not anticipate any impacts beyond those discussed in the GEIS because planned disturbances are largely within the operational area.
Site-Specific Activities The Decommissioning GEIS (NRC 2002; ML023470304) concluded a site-specific inquiry was necessary outside the operational area; however, in this case, there would be minimal decommissioning activities outside of the VNC operational area and none on previously undisturbed land (GE Hitachi 2023, ML23305A191; as updated by NorthStar 2024a, ML24220A200). The licensee will commit to implement an internal procedure, which provides cultural resources awareness, archaeological discovery procedures, and compliance with various local, state, and federal regulations.
The NRC staff reviewed NorthStars license amendment request to authorize major decommissioning activities, including dismantlement and demolition of the GETR and VBWR.
To address the potential impacts of such an authorization, the NRC staff identified the following measures to be conducted by NorthStar:
Updated DPR 523 Forms - California Department of Parks and Recreation Primary Record, as necessary.
o Consideration of any potentially suggested revisions from consulting parties.
Interpretive roadside display.
o Signage, to be placed on private property and viewable by the public, which briefly explains the history and significance of the VBWR and GETR.
A good faith effort will be made to coordinate with the Department of Energy (DOE) to post a video detailing the history of the VNC to the DOE VNC website (https://www.energy.gov/lm/vallecitos-nuclear-center-california-site); this video will also be posted to the NRC website.
o The video will contain information about the history and significance of the VBWR and GETR, including interviews with knowledgeable individuals, and be presented in a manner accessible and understandable to the general public.
Discovery situation training for VNC staff, providing education and direction on cultural resources discovery situations during applicable dismantlement and demolition activities.
o NorthStar will employ applicable internal procedures to ensure that staff working on authorized dismantlement or demolition activities related to this undertaking are educated and trained in policies and procedures in the case of a cultural
5 resources discovery situation; if no such procedure exists, NorthStar will prepare said training and add it to their internal procedures.
The preceding measures would be completed by NorthStar prior to dismantlement or demolition activities. Based on the measures described, the NRC staff have made a preliminary determination of no adverse effect pursuant to 36 CFR 800.5(b) since conditions are being imposed to avoid adverse effects.
Cumulative The NRC has also evaluated the impacts of past, present, and reasonably foreseeable future actions in the surrounding vicinity. The NRC staff concludes that, based on the previous level of disturbance, confined area of the undertaking, and intensity of the proposed activities, that when combined with past, present, and reasonably foreseeable future actions, the incremental contribution to a cumulative impact on historic and cultural resources by license termination and decommissioning would be minimal.
1.1.3 Persons and Agencies Consulted NHPA consultation was conducted pursuant to 36 CFR 800.8(c). The NRC staff contacted three federally recognized Indian Tribes (California Valley Miwok Tribe, Lytton Rancheria of California, and Wilton Rancheria) with historic and ancestral ties to the project vicinity to ensure that they were afforded the opportunity to identify their concerns, provide advice on the identification and evaluation of historic properties, including those of traditional religious, and cultural importance, and, if necessary, participate in the resolution of any adverse effects to such properties (ML25007A131). Ten state-recognized Tribes (Amah Mutsun Tribal Band, Amah Mutsun Tribal Band of Mission San Juan Bautista, Confederated Villages of Lisjan Nation, Costanoan Rumsen Carmel Tribe, Indian Canyon Mutsun Band of Costanoan, Muwekma Ohlone Tribe of the San Francisco Bay Area, Northern Valley Yokut / Ohlone Tribe, Tamien Nation, Ohlone Indian Tribe, and Wuksachi Indian Tribe / Eshom Valley Band) were also provided an opportunity to provide input on NRCs review (ML25007A131). The American Society of Mechanical Engineers (ASME) was also invited to consult (ML25105A009).
Responses to NRCs original consultation letter with a finding of adverse effect received responses from the California Valley Miwok (ML25069A584), Confederated Villages of Lisjan Nation (ML25069A685, ML25167A229, and ML25167A227), Amah Mutsun Tribal Band (ML25108A094), and Tamien Nation (ML25092A007). A response was also received from the ASME (ML25134A247).
The NRC staff also consulted upon the NRCs original finding of adverse effect with the CA SHPO (ML24331A229) and the Advisory Council on Historic Preservation (ACHP)
(ML25051A012). The ACHP responded (ML25237A189), as well as the CA SHPO (ML25045A081). The CA SHPO was unable to concur with the NRC staffs finding, and requested additional and clarifying information, as well as an expanded APE to include the entire VNC. The aforementioned consulting parties, as well as the public, will have an opportunity to review a draft of the historic and cultural resources section of this EA.
6 References GE Hitachi 2023 License Termination Plan for the Vallecitos Boiling Water Reactor License DPR-1, Enclosure 1, VBWR Environmental Report. Prepared by Surf to Snow Environmental, San Ramon, CA.
National Park Service 1997 National Register Bulletin 15 - How to Apply the National Register Criteria for Evaluation. Available online:
https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf NorthStar 2024a Update to License Termination Plan for Vallecitos Boiling Water Reactor -
Environmental Report. NorthStar Vallecitos, Sunol, CA.
2024b License Amendment Request - Historic and Cultural Resources Review, Vallecitos Boiling Water Reactor and General Electric Test Reactor. NorthStar Vallecitos, Sunol, CA.
NRC 2002 Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors, Supplement 1, NUREG-0586.
SEARCH 2023 Final Report, Historic Architectural Survey at Vallecitos Nuclear Center, Alameda County, California. Project No. E22099. Report authored by Anna Downing, Liz Blackwell, and Allen Kent. SEARCH, Pensacola, FL.
2025 Technical Report, Architectural History Survey of Vallecitos Nuclear Center, Alameda County, California. Project No. 240079. Report authored by Anna Suphanniam, Brittaney London, Chris Robinson, and Allen Kent. SEARCH, Pensacola, FL.