ML18215A187

Unit 1 Request for Partial Site Release

ML18215A187
Person / Time
Site:	Fort Calhoun
Issue date:	06/29/2018
From:	Fisher M J Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LIC-18-0023
Download: ML18215A187 (19)

Text

-~ **** ._._ -_. Omaha Public Po w er Distr i c t June 29, 2018 LIC-18-0023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054 10 CFR 50.83(b)

Subject:

Fort Calhoun Station, Unit 1 Request for Partial s;te Release

Reference:

1. Letter from OPPD (M. J. Fisher) to USN RC (Document Control Desk), "Fort Calhoun Station , Unit No. 1, Post-Shutdown Decommissioning Activities Report ," dated March 30 , 2017 (LIC-17-0033)(ML 17089A759)

Omaha Public Power District (OPPD), the licensee for Fort Calhoun Station (FCS), is requesting approval to remove a portion of the site from the Part 50 License (License No. DPR-40). Specifically , OPPD intends to remove/release three non-impacted survey units northwest of FCS from its Part 50 license in accordance with 10 CFR 50.83(b), "Release of part of a power reactor facility or site for unrestricted use." This activity is described in LIC-17-0033 , Fort Calhoun Station, Unit No. 1 , FCS Post Shutdown Decommissioning Activities Report (Reference 1 ). Enclosure 1 , " Supporting Information for Request for Partial Site Release ," provides the supporting informat i on for a partial release of the site for unrestricted use before receiving approval of the License Termination Plan (LTP) in accordance with the provisions of 10 CFR 50.83(b ). Enclosure 1 includes a description of the property and evaluation of the effect of r eleasing this property. The evaluation concludes that all applicable regulatory requirements will continue to be met and no change to the FCS Part 50 License is required. Enclosure 2 is a Computer Disk containing the non-NRC references from Enclosure

1. These references support the summary and conclusions described in Enclosure

1. There are no regulatory commitments to the NRC made in this letter. OPPD requests NRC approval of this request by March 29, 2019.

U.S. Nuclear Regulatory Commission LIC-18-0023 Page 2 If you should have any questions regarding this matter, please contact Mr. Bradley H. Blome -Director License & Regulatory Assurance at ( 402) 533-6041.

Respectfully, ;,;.6JL; lh~) .; ) Mary J. Fisher Vice President-Energy Production and Nuclear Decommissioning MJF/cac

Enclosures:

1. Supporting Information for Request for Partial Site Release 2. Computer Disk containing non-NRC referenced documents c: K. M. Kennedy , NRC Regional Administrator, Region IV J. D. Parrott , NRC Senior Project Manager R. S. Browder , NRC Senior Health Physicist, Region IV LIC-18-00 2 3 Enclosure 1 , Page 1 Purpose Fort Calhoun Station Supporting Information for Request for Partial Site Release The purpose of this report is to inform the Nuclear Regulatory Commission (NRC) of Omaha Public Power District's (OPPD) intent to remove a portion of the Fort Calhoun Station (FCS) site from the Part 50 license (License No. DPR-40). Specifically , OPPD intends to remove/release three (3) non-impacted survey units from its Part 50 License in accordance with 10 CFR 50.83(b) "Release of Part of a Power Reactor Facility or Site for Unrestricted Use" and 1 O CFR 100 , " Release Site Criteria." OPPD has reviewed and assessed the subject property to ensure that the subject land area will have no adverse impact of the ability of the site in aggregate to meet 10 CFR 20, Subpart E, criteria for unrestricted release. This report contains a summary of the assessment performed, as well as a summary of the characterization surveys performed in these survey units. It is noted that this report does not contain the Final Status Survey (FSS) report for this area because the survey units within this area are characterized as non-impacted and as such , no statistical tests, scan and static measurement or elevated measurement compa r ison are required.

Figure 1 provides a description of the site's owner controlled area and Figures 2, 3, 4 and 5 depict an overview of all the survey unit boundaries and the site boundary/subject non-impacted survey unit sample coordinates, respectively.

These figures do not include a depiction of the easement properties located in Iowa or located east of the western Missouri river boundary.

LIC-18-0023 Enclosure 1 Page 2 Figure 1-Fort Calhoun Station Owner Controlled Area LIC-18-0023 Enclosure 1 Page 3 Legend II S i te Boundary S i ou x City . Figure 2-Non-Impacted Open Land Survey Units Ced . Ott u m wa Par1a l s , te Release StNey U nts Fort ca111oun B lair. N E Date ai/2112018

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LIC-18-0023 Enclosure 1 Page 4 P.nar s e Release Suvey unt 1 Fatcalhoon Siar , NE 00/2112018 18062132 C Figure 3 -Site Boundaries/Subject Non-Impacted Survey Unit Sample Coordinates , Unit 1 LIC-18-0023 E ncl osu re 1 Pa g e 5 P.na l S tt e Release StJVey U ni 2 Fort Ca t llOUn B l ar r. N E 06/2012018 E.'ff .. RG\'SOW~ 21 b Figure 4-Site Boundaries/Subject Non-Impacted Survey Unit Sample Coordinates, Un i t 2 LIC-18-0023 Enclo s ure 1 Page 6 Figure 5 -Site Boundaries/Subject Non-Impacted Survey Unit Sample Coordinates , Unit 3 LI C-1 8-00 23 En cl osure 1 Pag e 7 Background FCS consists of one Pressurized Water Reactor (PWR). The station is located near the city of Fort Calhoun on the eastern boarder of central Nebraska. The site location is on the banks of the Missouri River approximately 19 miles North of Omaha , Nebraska and 4 miles south of Blair , Nebraska. The station is comprised of a Combustion Engineering pressurized water reactor with supporting facilities.

The primary coolant system consisted of two heat transfer loops. Each loop contained one steam generator and two reactor coolant pumps with associated piping and valves. In addition , the primary coolant system included a pressurizer , pressurizer relief tank, interconnecting piping, and the instrumentation necessary for operational control. All major components of the primary coolant system are located within t h e containment building. T he construction permit was issued by Atomic Energy Commission (AEC) on June 7 , 1 968, and operating license was issued August 9 , 1973. The plant began commercial operation on September 26 , 1 973. A l i cense was requested to operate the facility at power levels up to and including 1420 core thermal megawatts (MWt) which corres p onded to a t urbine-generator output of 481 MWe. The license was then amended to allow operation at power levels up to and including 1500 core thermal megawatts (MWt) which corresponded to a turbine-generator output of nominal 533. 7 MWe at 0.90 powe r factor. On June 24 , 2016 and updated on August 25, 2016 , FCS submitted the Certifications of Permanent Cessat i on of Power Operations (References 1 and 2) in accordance with 10 CFR Part 50.82 (a)(i). On November 13 , 2016 , FCS submitted the Certification of Permanent Removal of Fuel from the Reactor Vessel (Reference

3) to the NRC in accordance with 1 O CFR Part 50.82(a)(1 )(ii). On March 30 , 2017 , FCS submitted the Post-Shutdown Decommission i ng Act i vities Report (PS DAR) (Reference

4) and on March 31 , 2017 FCS submitted an updated Irradiated Fuel Management Plan (FMP) (Reference 5). Therefore , the 10 CFR Part 50 license for FCS no longer will permit operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR Part 50.82(a)(2).

LI C-1 8-002 3 E n clo su r e 1 P a ge 8 Evaluation of Effect of Proposed Release Fort Calhoun Station evaluated the effects of releasing a portion of land on the northwest portion of the owner controlled area totaling approximately 120-acres from the Part 50 License in accordance

• with the criteria specified in 10 CFR 50.83(a)(1-3) in order to ensure that FCS will continue to comply with all applicable statutory and regulatory requirements that may be affected by the release of the subject property. Specifically , OPPD's evaluation confirmed the following with respect to each of the regulatory areas identified in 10 CFR 50.83(a)(1 )(i)-(vi), (a)(2), and (a)(3): (a}(1) Evaluate the effects of releasing the property to ensure that: i. The dose to individual members of the public does not exceed the limits and standards of 10 CFR Part 20, Subpart D. OPPD cont r ols and monitors effluents to ensure radioactivity release to the environmen t is maintained ALARA and does not exceed federal release limit criteria.

Effluent controls include operation of radiation monitoring systems as well as an offsite environmental analysis program. The release of the northwest 120-acres of the Owner Controlled Area (OCA) does not change any controls used to comply with dose limits for individual members of the public and the conservatively estimated yearly dose to a member of the public is well below the 10 CFR Part 20 , Subpart D limits and standards.

A review of the Annual Effluent Report shows the Thermal Luminescent Device (TLD) read i ngs for the doses to members of the public are well below the regulatory l i mits set forth in both Environmental Protection Agency (EPA) and NRC dose limits. ii. There is no reduction in the effectiveness of emergency planning or physical security.

No credit is taken for the subject land in the Emergency Plan. However , the release was reviewed by Emergency Planning under the 10 CFR 50.54(q) and the Security Plan was reviewed under the 10 CFR 50.54(p) process. The evaluations concluded the release of the subject property has no adverse effect on either plan. Actions are assigned to Emergency Planning to incorporate any necessary changes in the exclusion area boundary into the Emergency Plan upon approval.

iii. Effluent releases remain within license conditions.

FCS programs to monitor and measure effluent releases within license conditions remain in effect and the early release of the subject property does not have an impact on these programs. Effluent monitoring conditions will remain in effect in accordance with license conditions. Environmental dose monitoring locations will LI C-1 8-002 3 En cl osure 1 Page 9 not change as a result of this proposed land release. Therefore, the effluent releases from FCS will remain in accordance with license conditions.

iv. The environmental monitoring program and offsite dose calculation manual (ODCM) are revised to account for the changes. Changes to the site boundary have the potential to affect concentrations in offsite dose pathways.

The FCS ODCM has been evaluated and will be updated to address reduced distance to the affected site boundary and potential land use in conjunction with implementation of partial site release request. Occupancy factors remain unchanged with the subject land release. The Environmental Impact Statement is not affected by the subject land release. There are no expected changes to the external appearance of the plant; changes to waste processing

changes in land or water usage; changes in water or air quality; changes in radiological impact; changes to historical or archeological areas. The socioeconomic impact of the release is balanced as the farmer who leases the land for row crops may be able to continue to do so after the release approval.

If any other development were to be undertaken in the future , the economic impact on the community could be improved. Any development would be subject to the construction and permitting for the laws of the state of Nebraska after the land release with the subject land being released from the provisions of the Part 50 license. v. The siting criteria for 10 CFR 100 continue to be met. The release of the subject property has been reviewed with respect to the siting criteria in 10 CFR 100 and it has been determined that the requirements of 10 CFR 100 are either not impacted or are not applicable.

The radiological Exclusion Area Boundary (EAB) at FCS is being updated to approximately 464 meters per engineering calculations (Reference 17). The dose at that distance from the Auxiliary Building effluent stack is well below the 10 CFR 100 criteria of 25 rem in two hours or 300 rem to the thyroid in that same time period. The member of the public that is analyzed to receive the highest dose is postulated t o receive 1 mrem total effective dose equivalent (TEDE) from an accident or event analysis.

FCS will continue to maintain the ability to remove members of the public from the exclusion area in the case of radiological emergency , which is approximately 436 meters closer to the plant than the subject land. vi. All other applicable statutory and regulatory requirements continue to be met. There are no significant changes to the FCS policies and procedures to ensure tha t statutory and regulatory requirements continued to be met as a result of this early release of the subject property.

LIC-1 8-00 2 3 Enclosure 1 Page 10 In summary , the proposed release of the approximately 120-acres from the Part 50 License will not have any impact on FCS continued compliance with applicable NRC standards. (a)(2) Perform a historical site assessment of the part of the facility or site to be released.

In accordance with guidance provided in NUREG-1575 , "Multi Agency Radiation Survey and Site Investigation Manual (MARSSIM)" (Reference 6), section 3.0 , a Historical Site Assessment (HSA) (Reference

15) was performed for all areas outside of operational structures and documented in 2016 after FCS was permanently taken offline for decommissioning.

Historical information , including any 10 CFR 50.75(g) files , employee interviews , radiological incident reports , pre-operational survey data , spill reports, special surveys , operational survey records, and Annual Radiological Operating Reports (including sampling of air, groundwater , milk, fish, and surface vegetation) were reviewed and compiled for this investigation. The HSA was a detailed investigation of all non-operational areas of the OCA to collect existing information for the site and its surroundings. The HSA focused on historical events and routine operational processes that could have resulted in contamination of onsite buildings outside of the Protected Area (PA); surface and subsurface soils within the PA; as well as open land areas, subsurface soils outside of the PA , but within the OCA. The information compiled by the HSA was used to establish initial area survey unit classification of the subject land. The scope of the HSA includes potential contamination from radioactive materials, hazardous materials, and environmental contaminants.

The HSA investigation was designed to obtain sufficient information to provide initial classification of site land areas and structures as impacted or non-impacted.

Impacted areas have a potent i al for contamination (based on historical data) or contain known contamination (based on preliminary radiological surveillance). MARSSIM defines impacted areas as those areas where there is no reasonable possibility of residual contamination. Based on a review of the operating history of the facility , historical incidents, and opera t ional radiological surveys as documented in the HSA, as well as subsequent characterization surveys discussed in the next section, the subject open land areas in the northwest corner of the OCA were deemed not impacted by licensed activities or mater i als. Therefore , it was determined that the " non-impacted" classification is appropriate. (a)(3) Perform surveys adequate to demonstrate compliance with the radiological criter i a for unrestricted use specified in 10 CFR 20.1402 for impacted areas. MARSSIM Section 2.5.2 states , " Non-impacted areas represent areas where all of the information necessary to demonstrate compliance is available from existing sources. For these areas, no statistical tests are considered necessary." Additionally, Table 2.2. of MARSSIM , "Recommended Conditions for Demonstrating Compliance Based on LIC-18-0023 Enclosure 1 Page 11 Survey Unit Classification for a Final Status Survey ," requires no elevated measurement comparison, no sampling, and/or direct measurements and no scanning to be performed in non-impacted areas. Despite this available waiver, a comprehensive characterization was performed. The site release criteria for the subject land at FCS correspond to the 10 CFR 20.1402 criteria for unrestricted use. The residual radioactivity, including that from ground water sources , that is distinguishable from background, must not cause the TEDE to an average member of the critical group to exceed 25 mrem/yr. The residual radioactivity must also be reduced to levels that are ALARA. The characterization survey was designed and executed using the guidance provided in MARSSIM and NUREG-1757 , Volume 2, Revision 1 , "Consolidated Decommissioning Guidance-Characterization, Survey, and Determination of Radiological Criteria, Final Report" (Reference 7). Analyses of background radiation and Cs-137 in background (Reference 10), radionuclides of concern (Reference 9), and minimum detectable concentration (Reference

11) were completed and utilized in survey design. Both Data Quality Objectives and survey methodology were included in detailed survey packages, L4-001 , L4-002, and L4-003 (Reference 14). These describe the process, organization, functional sample activities, Data Quality Objective process, and measures necessary to conduct surveys in the field. The surveys were carried out via those detailed survey package documents.

Areas classified as non-impacted received surveys developed to include randomly chosen and biased survey measurements locations and scan areas. Only one area was identified for a biased survey location for a static, Canberra In-Situ Object Counting System (ISCOS) (Reference

12) measurement.

This was based on known information and due to terrain constraints. Fewer ISOCS measurements were able to be completed in the treed areas of one of the survey units; therefore, the judgmental location was selected at an accessible area inside the treed portion of that sample unit. Utilizing the MARSSIM Class 3 model for survey design, measurement or sample locations were prescribed at randomly chosen locations. In April 2018, sufficient survey coverage (gamma scans performed over 1 % of the accessible surface areas) and an adequate number of samples (14 per unit) were obtained in the subject survey units to serve as the basis for the " non-impacted" classification.

Because there is no history of or credible pathway for subsurface soil contamination, the survey focused only on surface (0 to 15 cm) soil. Within each of the survey units specified, no soil samples greater than 15 cm in depth were obtained. The characterization survey of each unit consisted of both qualitative evaluations and quantitative analysis results. The qualitative evaluation consisted of static measurements using the ISOCS. Verification gamma scans using a Nal detector were also performed with speeds and distances in accordance with Reference

11. Minimum Detectable Concentrations (MDC) and gamma scanning sensitivities were estimated based on the assumed geometry and the potential plant-derived gamma-emitting radionuclides that may be present. Quantitative analysis results were obtained from radionuclide specific analysis of surface soil media using a calibrated counting geometry.

LIC-18-0023 Enclosure 1 Page 12 Analysis times were set to achieve the required MDCs that were based on expected Cs-1 37 background due to global fallout. The minimum number of randomly located direct measurements and soil samples was chosen utilizing MARSSIM guidance and the Sign test with a MARSSIM Class 3 methodology and a and J3 decision errors of 0.05 or 5%. Surface scanning using a Nal detector was performed in a square area around a randomly chosen center point to approximate at least one percent of the total area of a given survey unit. Each square scan area measured between 10 and 12 meters on each side. ISOCS measurements were taken at all locations at which terrain allowed access. As discussed, one additional ISOCS location was selected based on the terrain's similarity to those locations which were inaccessible to the ISOCS equipment.

The " non-impacted" subject land area at FCS totals 120.32 acres. None of this land area was considered inaccessible from a sampling standpoint.

Any reference to inaccessible here, r efers to the inability to transport the sensitive ISOCS instrument through treed, blocked , or excessively uneven terrain. As such , all areas of the subject land a r ea were able to be scanned by Nal detector and a soil sample obtained.

However , in the random generation of sample points, a few locations(<

10%) were thrown out and a new point randomly generated due to the safety of the personnel access or a portion of the scan area landing in the Missouri River. For the Nal detector scanned areas, post-sampling data review was conducted on the approximately 30 , 000 data points which were recorded at one second intervals with a Trimble Global Positioning System (GPS) unit. The analysis of the data utilized an action level of minimum detectable count rate (MDCR) plus background.

Any points which exceeded that threshold and in which an adjacent point also exceeded the threshold would be re-surveyed. Background data was obtained at several locations determined to be similar in both land-use and geology. Three distinct types were identified (field, treed, and sand). Action levels were applied to each background type. The scans did not i dentify any locations that required further survey or examination.

All areas surveyed showed count rates consistent with the expected background levels for that area type (see Attachment 5 of Reference 13 , "Partial Site Release Radiological Measurements."). The ISOCS locations scanned did not identify any FCS related radioactivity.

Low-levels of Cs-137 were identified in low and relatively undisturbed locations ( e.g. wooded areas) consistent with the expected residual levels from historical nuclear weapons testing fallout. See " Evaluation of Cs-137 Global Fallout in Soils at Fort Calhoun Station" (Reference 10). Additional detail on the survey results of the radiological analysis of each measurement and soil sample obtained during the characterization of the subject non-impacted open land survey units are presented in the Fort Calhoun Station, " Partial Site Release Radiological Measurements" (Reference 13). Based on the results of the characterization surveys performed of the subject non-impacted open land area, it can be concluded that a non-impacted classification for these areas is appropriate as all measurements were less than the established background values (less the mean plus 2cr). Cs-137 was the only radionuclide positively identified that could be potentially LI C-18-0023 Enclosure 1 Page 13 classified as plant-derived

however, the concentrations observed were well with the range of activity defined as background due to global fallout. Non-impacted areas are defined in MARSSIM as areas that have no reasonable potent i al for residual contamination , no radiological impact from site operations and are typically identified during the HSA. FCS has found no evidence of using, storing , or burying radioactive materials in the subject property.

Therefore , based on sample measurements and historical use information, it can be concluded that the release of the subject land area will have no adverse impact on the ability of FCS to meet the Part 20 , Subpart E requirements for unrestricted release. Description of the Property For non-impacted areas, 10 CFR 50.83 (b )(2) requires a description of the part of the facility or site to be released.

The owner-controlled site is approximately 660 acres; 565 acres of this area is on the alluvial flood plain of the Missouri River , and the remainder is part of the bluff system on the southwest side of the river. An additional exclusion area of 582 acres is included on the northeast bank of the river directly opposite the plant buildings.

This additional exclusion area is provided by means of perpetual easements which allows OPPD to restrict or prohibit access should evacuation be necessary. More specifically on October 28, 1969, and on October 24, 1973, the owners of property located across the Missouri River from OPPD's Fort Calhoun facility executed easements in perpetuity to OPPD. The property that is subject to this release is an approximately 120-acre parcel of uninhabited, undeveloped land that has not been negatively impacted by FCS operations or subsequent decommissioning activities.

The FCS property is located in the eastern portion of central Nebraska in Washington County, Nebraska. Area located in the East half of the Southwest quarter of Section 17 , Township 18 North , Range 12 East and the East half of the Northeast quarter of the northwest quarter and East half of the Southeast quarter of the northwest of Section 20, Township 18 North, Range 12 East. The sites location is on the banks of the Missouri River approximately 19.4 miles North of Omaha, Nebraska and 4 miles south of Blair, Nebraska. The closest residence is 0.6 miles (==965 meters) from the center of FCSs containment building. Based upon the information compiled in the HSA , the three (3) open land survey units received an initial classification as " non-impacted." Non-impacted areas have no reasonable potential for residual contamination because of historical information indica t es there was no known impact from site operations. These outlying areas have no impact from site operations based upon the location(s) of licensed operation , site use , topography, site discharge locations and other site physical characteristics. These areas are not required to be surveyed for demonstrating compliance beyond any characterization surveys performed to provide a basis for the classification.

The 120-acre parcel has limited access for personnel or vehicle transit due to controlled access and use of the parcel for agricultural purposes.

LIC-1 8-00 2 3 Enclosure 1 Page 14 Schedule for Subject Property Release For the three non-impacted areas, 10 CFR 50.83(b)(3) requires the schedule for the release of the property. OPPD intends to begin undertaking activities associated with the release of the subject property from the FCS Part 50 License in April 2019. Therefore , OPPD requests the NRC approve the acceptability of the release of the subject property from Part 50 License by March 29 , 2019. Results of 10 CFR 50.59 Evaluation 1 0 CFR 50.83(b )( 4) requires for non-impacted areas that the licensee submit the results of the evaluation performed in accordance with 10 CFR 50.59. The assessments of the release of the subject property i s as follows: The partial site release involves approximately 120-acres of non-impacted land out of the approximate 660 acres the site owns. The release does not involve property that is actively used by the plant for routine or decommissioning operations or that is needed for the site's emergency plan. The 10 CFR 50.59 review (Screening

1. 18-049) assessed the impact of the change in the site boundary on offsite dose calculation and effluent releases and conclude that the change:

• Does not adversely affect any design function as described in the Defueled Safety Analysis Report (DSAR)(Reference

8)

• Does not adversely affect how a design function as described in the DSAR is performed or controlled

• Does not revise or replace an evaluation method used to establish design basis of safety analysis , and

• Does not involve a test or experiment not described in the DSAR. Environmental Impacts Under 10 CFR 50.83(b )(5), a request for NRC approval of a r elease of non-impacted areas must include the reasons for concluding that the environmental impacts assoc i ated with the proposed release of property will be bounded by appropriate previously issued Environmental Impact Statements in the Generic Environmental I mpact Statement for FCS. (Reference

16) OPPD has evaluated the environmental impacts associated with the proposed release o f t he subject land and considered those impacts in light of the Final Environmental Impact Statement (FEIS). The evaluation did not identify any significant new environmental i mpacts or significant changes from the environmental impacts prev i ously assessed by t he NRC. In particular , the evaluation found as follows.

• The land transfer will have no more than a negligible increase in offsite dose consequences and no change in effluent releases.

LIC-1 8-002 3 Enclosure 1 Page 15

• The OPPD r adiological monitoring program will account for the revised site area boundary, and no increases in effects are anticipated.

Accordingly , OPPD concludes that the environmental impacts associated with the proposed release of the subject property are bounded by the NRC's previous or current reviews , of the FCS facility.

Addit i onal Areas to be Addressed to Support Release of the Subject Property Statement of Dismantling Activities No dismantlement activities are required in the subject survey units. Potential for Cross-Contamination from Subsequent Activities The potential for cross-contamination of the subject non-impacted areas due to subsequent decommissioning activities is diminutive. The subject areas are distant and in a remote location relative to any decommissioning activities. Isolation and control measures in owner-controlled areas adjacent to the subject property will be implemented through approved procedures and will remain in force throughout site final site survey activities and until there is no undue risk of recontamination from decommissioning.

In the event that isolation and control measures established for those survey areas are compromised, evaluations will be performed and documented to confirm the no radioactive material was introduced into the area that would affect the results of the FSS. Given the isolation and controls established for the FSS areas adjacent to the subject property , i t is highly unlikely that radioactive materials could be introduced into the subject property borders. Radioactive material generated during the decommissioning process will be handled and controlled in a manner to prevent contamination of impac t ed areas. These controls include contamination containment measures , dust control measures , storm water runoff control measures, and proper radiological protection implementation. Impact of Releasing the Subject Property of Part 50 License Basis The license basis for FCS includes the maintenance of certain programs to fulfill regulatory requirements and functional responsibilities.

Throughout decommissioning , t he programs will be modified as necessary and terminated when the applicable concern i s no longer relevant.

These program changes are implemented using the change process specified for each type of program. The methodology for releasing land r equires a review and assessment of the impact on license program for the site lands r emaining within the domain of the Part 50 License.

• The Technical Specifications are not impacted by the early release of the subject property.

LIC-1 8-0023 Enclosure 1 Page 16

• The Defueled Safety Analysis Report (DSAR) will require minor changes to describe the reduced site licensed area boundaries resulting from the release of t he subject property from the Part 50 License. Also , a change to the DSAR safety analysis for the exclusion area boundary requires updating resulting in an overall dose reduction (not adverse).

• The Radiological Groundwater Protection Program will not be affected by the early release of the subject property.

• The Fire Protection Program will not be affected by early release of the subject property.

• The Training Program will not be affected by the early release of the subject property.

Conclusion The release of the subject property is part of OPPD's overall efforts to terminate the FCS Part 50 License and to achieve unrestricted release of the entire site (with the exception of the ISFSI area) in accordance with the criteria in subpart E of 10 CFR 20. In addition, 10 CFR 50.82(a)(11) establishes the criteria to be used by the NRC for terminating license of a power reactor facility. These criteria include (1) dismantlement has been performed in accordance with the approved license termination plan and, (2) the final radiation survey and associated documentation that the facility and site have met the criteria for decommissioning in 10 CFR 20 , Subpart E. This early release of the subject property area also supports the process of l icense termination by demonstrating that this portion of the site lands can be released from FCS license. This report along with future reports provide documentation that demolition activities have been performed in accordance with the station procedures and the characterization survey confirms the residual radioactivity in each survey unit meets the established criteria. The action of the early release of the subject land supports the overall license termination process in accordance with NRC regulations. In summary, based on the considerations discussed above, the release of the subject property from the FCS Part 50 License has no impact of OPPD's continued compliance with applicable NRC regulatory standards. OPPD has determined that we have adequately classified the property to be released as " non-impacted." Accordingly , OPPD is r equesting the NRC to approve the requested release.

LIC-18-002 3 Enclosure 1 Page 17 References

1. Letter from OPPD (T. Burke) to USNRC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated June 24 , 2016 (LIC-16-0043) (ML 16176A213)

2. Letter from OPPD (T. Burke) to USN RC (Document Control Desk), "Certification of Permanent Cessation of Power Operations

," dated August 25, 2016 (LIC-16-0067) (ML 16242A 127) 3. Letter from OPPD (T. Burke) to USNRC (Document Control Desk), "Certification of Permanent Removal of Fuel from the Reactor" dated November 13, 2016 (LIC-16-0074) (ML 16319A254)

4. Letter from OPPD (M. Fisher) to USNRC (Document Control Desk), Shutdown Decommissioning Activities Report (PSDAR)," dated March 30, 2017 (LIC-17-0033)

5. Letter from OPPD (M. Fisher) to USNRC (Document Control Desk),"lrradiated Fuel Management Plan ," dated March 31 , 2017 (LIC-17-0031) 6. U.S. Nuclear Regulatory Commission NUREG-1575 , Revision 1 , " Multi-Agency Radiation Survey and S i te Investigation Manual (MARSSIM)" -August 2000 7. U.S. Nuclear Regulatory Commission NUREG-1757 , Volume 2 , Revision 1, " Consolidated Decommissioning Guidance -Characterization , Survey, and Determination of Radiological Criteria, Final Report" -September 2006 8. Fort Calhoun Station " Defueled Safety Analysis Report (DSAR)," March 2018 9. FC-18-002 , "Potential Radionuclides of Concern During the Decommissioning of Fort Calhoun Station." Blair: Fort Calhoun Station, 2018. 10. FC-1 8-003 , "Evaluation of Cs-137 Global Fallout in Soils at Fort Calhoun Station." Blair: Fort Calhoun Station, 2018. 11. FC-18-006 , "Soil Minimum Detectable Concentrations for 2x2 Nal Probes." Blair: Fort Calhoun Station , 2018. 12. FC-18-009 , " Use of In-Situ Gamma Spectroscopy for Characterization." Blair: Fort Calhoun Station , 2018. 13. FC-18-010 , "Partial Site Release Radiological Measurements

." Blair: Fort Calhoun Station , 2018. 14. FCS Partial Site Release Survey Packages and Preparation Instructions. Blair: Fort Calhoun Station , 2018. 15. TSSD. Fort Calhoun Station Limited Radiological and Non-Radiological Site Characterization Survey Reports. Oakland: TSSD Services, 2017. 16. NUREG-1437 , Generic Environmental Impact Statement for License Renewal of Nuclear Plants , Supplement 12 , Regarding Fort Calhoun Nuclear Power Station , August 2007. 17. EC 69954 , " Partial Site Release-Phase I." Blair: Fort Calhoun Station , 2018.