ML23333A049

Final Fort Calhoun License Termination Plan Environmental Assessment

ML23333A049
Person / Time
Site:	Fort Calhoun
Issue date:	12/31/2023
From:	NRC/NMSS/DREFS
To:
References
NRC-2022-0127
Download: ML23333A049 (72)

Text

ML23333A049 Environmental Assessment for the License Termination Plan for Fort Calhoun Station, Unit 1 in Washington County, Nebraska Completed: December 2023 Environmental Center of Expertise Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety & Safeguards

ML23333A049 Environmental Assessment for the License Termination Plan for Fort Calhoun Station, Unit 1 in Washington County, Nebraska Completed: December 2023 Office of Nuclear Material Safety & Safeguards

Table of Contents ABBREVIATIONS AND ACRONYMS ....................................................................................... vii 1 INTRODUCTION .............................................................................................................. 1-1 1.1 Proposed Action ....................................................................................................... 1-3 1.2 Purpose of and Need for the Proposed Action ......................................................... 1-3 1.3 Alternative to the Proposed Action ........................................................................... 1-4 1.4 Scope of the Environmental Analysis ....................................................................... 1-4 2 PROPOSED ACTION AND ALTERNATIVES ................................................................. 2-1 2.1 Proposed Action ....................................................................................................... 2-1 2.1.1 History of the FCS License ........................................................................... 2-1 2.1.2 Decommissioning Activities ........................................................................ 2-03 2.2 Alternatives............................................................................................................. 2-66 3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS................................. 3-1 3.1 Land Use .................................................................................................................. 3-2 3.1.1 Land Use including Site Description and Vicinity ......................................... 3-2 3.1.2 Land-Use Direct and Indirect Impacts .......................................................... 3-3 3.2 Visual and Scenic Resources/Aesthetics ................................................................. 3-5 3.2.1 Description of the Visual and Scenic Affected Environment ......................... 3-5 3.2.2 Visual and Scenic Resources Direct and Indirect Impacts ........................... 3-5 3.3 Climatology, Meteorology, and Air Quality ............................................................... 3-6 3.3.1 Climatology and Meteorology ....................................................................... 3-6 3.3.2 Air Quality ..................................................................................................... 3-6 3.3.3 Greenhouse Gases and Climate Change ..................................................... 3-6 3.3.4 Direct and Indirect Impacts ........................................................................... 3-7 3.4 Noise ........................................................................................................................ 3-9 3.4.1 Noise Levels ................................................................................................. 3-9 3.4.2 Noise Direct and Indirect Impacts ................................................................. 3-9 3.5 Geology and Soils .................................................................................................... 3-9 3.5.1 Regional and Site-Specific Geology ............................................................. 3-9 3.5.2 Regional, Site-Specific Geology and Soils Direct and Indirect Impacts ..... 3-10 3.6 Water Resources.................................................................................................... 3-10 3.6.1 Surface Water............................................................................................. 3-10 3.6.2 Groundwater ............................................................................................... 3-13 3.7 Historic and Cultural Resources ............................................................................. 3-14 3.7.1 Historic and Cultural Resources Affected Environment .............................. 3-14 3.7.2 Historic and Cultural Resources Direct and Indirect Impacts ..................... 3-15 3.8 Ecological Resources ............................................................................................. 3-16 3.8.1 Terrestrial Resources ................................................................................. 3-16 3.8.2 Aquatic Resources ..................................................................................... 3-25 3.9 Socioeconomics ..................................................................................................... 3-28 3.9.1 Socioeconomic Characteristics of the Site Vicinity ..................................... 3-28 3.9.2 Socioeconomic Direct and Indirect Impacts ............................................... 3-28 December 2023 iii

3.10 Public and Occupational Health ............................................................................. 3-29 3.10.1 Existing Radiological Conditions ................................................................ 3-30 3.10.2 Public and Occupational Dose Health and Safety Direct and Indirect Impacts ....................................................................................................... 3-30 3.11 Transportation and Traffic ...................................................................................... 3-31 3.11.1 Transportation Affected Environment ......................................................... 3-31 3.11.2 Transportation Direct and Indirect Impacts ................................................. 3-32 3.12 Environmental Justice ............................................................................................ 3-33 3.12.1 Minority Populations in the Vicinity of the FCS Site .................................... 3-33 3.12.2 Low-income Populations in the Vicinity of the FCS Site ............................. 3-34 3.12.3 Direct and Indirect Impacts ......................................................................... 3-34 3.13 Waste Management ............................................................................................... 3-35 3.13.1 Radioactive Waste...................................................................................... 3-35 3.13.2 Nonradioactive Waste ................................................................................ 3-36 3.13.3 Waste Management Direct and Indirect Impacts ........................................ 3-37 3.14 Cumulative Effects ................................................................................................. 3-38 3.15 Summary of Environmental Consequences ........................................................... 3-40 4 CONSULTATION AND COORDINATION ....................................................................... 4-1 4.1 State Review ............................................................................................................ 4-1 4.2 National Historic Preservation Act Section 106 Consultation ................................... 4-1 4.3 Endangered Species Act Section 7 Consultation ..................................................... 4-1 5 CONCLUSIONS AND RECOMMENDATIONS ................................................................ 5-1 6 LIST OF PREPARERS .................................................................................................... 6-1 7 REFERENCES ................................................................................................................. 7-1 December 2023 iv

Figures Figure 1. General Timeline of Decommissioning Activities .................................................. 1-2 Figure 2. FCS Unit 1 Site Location ....................................................................................... 2-0 Figure 3. FCS Owner-Controlled Areas ................................................................................ 2-0 Figure 4. FCS End State ...................................................................................................... 3-4 Figure 5. Extent of 2011 Flooding Event ............................................................................ 3-11 Figure 6. Location of HESCO Flood Barrier ....................................................................... 3-12 Figure 7. Waste Enclosures and Haul Paths ...................................................................... 3-32 Tables Table 1. Environmental Resource Areas Bounded by the Decommissioning GEIS............ 3-1 Table 2. Federally Listed Terrestrial Species at the FCS and in the Vicinity ..................... 3-17 Table 3. State-Listed Terrestrial Species at the FCS and in the Vicinity ........................... 3-18 Table 4. Summary of Decommissioning and License Termination Activity Impacts on the Listed Species at the FCS and in the Vicinity (NLAA) ................................... 3-21 Table 5. Summary of Decommissioning and License Termination Activity Impacts on the State-Listed Species at the FCS and in the Vicinity (Minimal Impacts)......... 3-23 Table 6. Federally Listed Aquatic Species at the FCS and in the Vicinity ......................... 3-25 Table 7. State-Listed Aquatic Species at the FCS and in the Vicinity ............................... 3-26 Table 8. Summary of Decommissioning and License Termination Activity Impacts on the Listed Species at the FCS and in the Vicinity (NLAA) ................................. 3-278 Table 9. Summary of Decommissioning and License Termination Activity Impacts on the State-Listed Species at the FCS and in the Vicinity (Minimal Impacts)....... 3-278 Table 10. Projected LLW Disposal Volumes ....................................................................... 3-36 Table 11. Projected Nonradioactive Waste Quantities ........................................................ 3-37 Table 12. Summary of LLW Disposal Facilities and Capacities .......................................... 3-37 Table 13. Summary of Environmental Consequences Specifically Identified in the GEIS .................................................................................................................... 3-40 December 2023 v

ABBREVIATIONS AND ACRONYMS

°C degrees Celsius

°F degrees Fahrenheit ac acre(s)

ALARA as low as is reasonably achievable BGEPA Bald and Golden Eagle Protection Act BMP best management practices CFR Code of Federal Regulations DCGL derived concentration guideline levels DECOM decommissioning EA Environmental Assessment EPA U.S. Environmental Protection Agency EFH essential fish habitat ESA Endangered Species Act of 1973 FCS Fort Calhoun Station, Unit 1 ft foot (feet) ft2 square feet FWS U.S. Fish and Wildlife Service GCRP U.S. Global Change Research Program GEIS Generic Environmental Impact Statement GTCC Greater-than-Class-C (waste) ha hectare(s) in inch(es)

IOF ISFSI operation facility ISFSI Independent Spent Fuel Storage Installation IPaC Information for Planning and Consultation km kilometer(s) kV kilovolt LLW low-level radioactive waste LTP License Termination Plan m meter(s) m2 square meters mi mile(s)

MBTA Migratory Bird Treaty Act of 1918 MMI Modified Mercalli Intensity MOU Memorandum of Understanding MSA Magnuson-Stevens Fishery Conservation and Management Act mrem millirem mSv millisievert NEPA National Environmental Policy Act of 1969 December 2023 vii

Ne SHPO Nebraska State Historic Preservation Office NLAA not likely to adversely affect NPDES National Pollutant Discharge Elimination System NSHS Nebraska State Historical Society NRC U.S. Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual OPPD Omaha Public Power District PSDAR Post-Shutdown Decommissioning Activities Report PWR pressurized-water reactor REMP Radiological Environmental Monitoring Program RGPP Radiological Groundwater Protection Program RPP Radiation Protection Program SEIS supplemental environmental impact statment Sv Sievert TEDE Total Effective Dose Equivalent WCS Waste Control Specialists yr year(s)

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1 INTRODUCTION By letter dated August 3, 2021, the Omaha Public Power District (OPPD) submitted an application to the U.S. Nuclear Regulatory Commission (NRC or Commission) requesting a license amendment to approve the License Termination Plan (LTP) for the Fort Calhoun Station, Unit 1 (FCS), located in Washington County, Nebraska (OPPD 2021). The FCS is a commercial nuclear power plant that is licensed by the NRC, but it stopped operations in 2016.

OPPDs request, if granted, would add a condition to its license reflecting the NRCs approval of its LTP and establishing criteria for determining when changes to the LTP require prior NRC approval (OPPD 2021).

Submittal of the LTP is one of the final steps in the NRCs nuclear power reactor decommissioning process, which involves the safe removal of a facility from service and the reduction of residual radioactivity to a level that permits NRC license termination. Figure 1 provides a general timeline for the overall decommissioning process. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.82, Termination of license, provides the requirements for terminating power reactor licenses. Those requirements specify what must be included in a licensees LTP when submitted to the NRC for review and approval. The LTP describes the process the licensee will use to meet the requirements for terminating the license and releasing the site for unrestricted use.

The NRC will terminate the license if it determines that the site meets the performance-based criteria for unrestricted site release, in accordance with 10 CFR 20.1402, Radiological criteria for unrestricted use, and that the facility has been dismantled in accordance with the approved LTP. The portion of the site associated with the independent spent fuel storage installation (ISFSI) will remain under the NRCs regulatory jurisdiction. Although the terminology license termination is used throughout this environmental assessment (EA), the 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, license will continue in effect for the FCS ISFSI only. The FCS license will be considered terminated in all other aspects and will only apply to the site occupied by the FCS ISFSI. For simplicity, this EA will refer to terminating the license. When it does so, it means releasing the entire site, except for the ISFSI and the ISFSI Operating Facility (IOF), for unrestricted use. Until the OPPD has removed the spent fuel from the site and decommissioned the ISFSI, the license will remain in effect.

The NRC staff has prepared this EA to evaluate and document the potential environmental impacts resulting from the NRCs approval of OPPDs license amendment request and the subsequent implementation of the LTP. The NRC staff also is performing a detailed safety analysis of OPPDs license amendment request. The results of the safety analysis will be documented in a separate Safety Evaluation Report. The NRC decision whether to approve the license amendment request will be based on the results of the NRC staffs reviews documented in this EA and the Safety Evaluation Report.

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Figure 1. General Timeline of Decommissioning Activities (Source: NRC 2002)

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1.1 Proposed Action The proposed action is the review and subsequent approval, if appropriate, of the FCS LTP. In its license amendment request, the OPPD requested an amendment to the FCS license to add license conditions that (1) reflect the NRC staffs approval of the LTP and (2) provide criteria for when NRC approval is needed for subsequent LTP changes. If the NRC approves the LTP, approval will be issued in the form of an amendment to the FCS license that adds the requested license conditions.

1.2 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 by the OPPD, termination of the FCS operating license by the NRC, and subsequent release of the FCS site for unrestricted use. The NRC regulation at 10 CFR 50.82 sets forth the process for the licensee to decommission its nuclear power plant, including submission of the LTP. The NRC will approve the LTP, provided that the LTP meets the criteria in 10 CFR 50.82(a)(10).

The NRC staffs review and approval of the LTP is the regulatory mechanism by which the NRC ensures that final decommissioning activities are appropriately completed. As part of the LTP review process, the NRC staff determines whether the procedures and activities planned for completing decommissioning (e.g., adequacy of radiation release criteria and adequacy of the design of the final radiation survey) appear sufficient as described in the LTP.

The FCS intends to meet the criteria for unrestricted use. The NRCs performance-based radiological criteria for unrestricted release of a licensed site, as specified by 10 CFR 20.1402, is:

A site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a TEDE[1] to an average member of the critical group that does not exceed 25 millirem (mrem) (0.25 milliSievert [mSv]) per year, including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA). Determination of the levels which are ALARA must take into account consideration of any detriments, such as deaths from transportation accidents, expected to potentially result from decontamination and waste disposal.

The OPPD has proposed derived concentration guideline levels (DCGLs) to meet the 10 CFR 20.1402 criteria. The NRC staff must determine whether additional planning, investigation, or other activities by OPPD are necessary to support the NRCs decision on approving the LTP.

Once decommissioning has been completed, the NRC licenses have been terminated with the exception of the ISFSI site, and the site has been released for unrestricted use, the OPPD can make the FCS site available for another use.

1 Total Effective Dose Equivalent (TEDE) means the sum of the effective dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures). Dose equivalent means the product of the absorbed dose in tissue, quality factor, and all other necessary modifying factors at the location of interest. The units of dose equivalent are the rem and Sievert (Sv). (10 CFR 20.1003.)

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1.3 Alternative to the Proposed Action As an alternative to the proposed action, the NRC staff considered the no-action alternative.

Under the no-action alternative, the NRC would not approve the LTP or the license amendment request because regulatory requirements have not been met. Consequently, the FCS licenses would not be terminated, decommissioning and other onsite maintenance and operations activities involving the storage of spent nuclear fuel would continue, and the FCS site would not be released for unrestricted use. The NRC regulation at 10 CFR 50.82(a)(10) states that the Commission shall approve an LTP, by license amendment, if the LTP demonstrates that the remainder of the decommissioning activities will be performed in accordance with the NRCs regulations, will not be inimical to the common defense and security or to the health and safety of the public, and will not have a significant effect on the quality of the environment.

If the NRC was unable to approve the LTP because the regulatory requirements were not met, then the OPPD would have to take the necessary actions to ensure the regulations are met. The OPPD would need to take additional action to prepare an LTP that meets the requirements in 10 CFR 50.82(a)(10); the updated LTP would then need to be submitted to NRC for approval prior to license termination. Under this scenario, until the OPPD resubmits the LTP, activities at the FCS would likely continue and the environmental impacts would neither increase nor decrease as a result of the additional time required for the LTP resubmission.

1.4 Scope of the Environmental Analysis To fulfill its obligations under the National Environmental Policy Act (NEPA) of 1969, the NRC must evaluate the radiological and nonradiological environmental impacts associated with approval of the LTP and subsequent termination of the license. These evaluations involve an assessment of the impacts of remaining decommissioning and site restoration activities documented in the LTP and license termination activities (e.g., final site survey).

The NRC previously evaluated the potential environmental impacts of nuclear reactor decommissioning in NUREG-0586, Supplement 1, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (GEIS) (NRC 2002). The GEIS is used by NRC staff to evaluate environmental impacts that would occur during the decommissioning of nuclear power reactors. The GElS is considered "generic" in that it evaluates environmental impacts from decommissioning activities common to nuclear power reactor facilities. The GEIS addresses decommissioning of nuclear power reactors licensed by the NRC, including pressurized-water reactors (PWRs), boiling-water reactors, and multiple reactor stations. The generic analysis was based, in part, on experience with reactors that had already undergone or were undergoing decommissioning.

The FCS was not evaluated in the GEIS. The GEIS did evaluate the Maine Yankee Nuclear Power Plant, however. The Maine Yankee Nuclear Power Plant was an 860 megawatt-electric PWR designed by Combustion Engineering. The FCS is also a PWR designed by Combustion Engineering and, when operating, had a power level of 484 megawatts-electric. Because both facilities are PWRs designed by Combustion Engineering, they have similar designs and construction. Because the power level of Maine Yankee was higher than that of the FCS, the facility was an overall larger facility, meaning it had a larger footprint, required a larger volume of water intake, and generally had greater environmental effects Therefore, the environmental impacts of decommissioning Maine Yankee Nuclear Power Plant evaluated in the GEIS would bound the environmental impacts of decommissioning of the FCS because the smaller power level, footprint, water intake. Thus, the GEIS is applicable to the decommissioning of the FCS.

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The scope of the GEIS is based on decommissioning activities from the time that a licensee certifies it has permanently ceased power operations until the license is terminated. The NRC staff concluded in the GEIS that the environmental impacts of decommissioning, including license termination activities, can be determined generically for all nuclear power plants and will have SMALL impacts2 in all but six environmental resource areas. The GEIS concluded that two of these six resource areas (i.e., threatened, and endangered species and environmental justice) must always be evaluated on a site-specific basis in site-specific EAs, such as this EA for the FCS LTP. Depending on the site-specific circumstances, the following four additional resource areas are considered to be conditionally site specific: (1) offsite land use, (2) historic and cultural resources, (3) terrestrial ecology beyond the operational area, and (4) aquatic ecology beyond the operational area (NRC 2002).

The GEIS did not address the affected environment; cumulative impacts; climate change and greenhouse gases (GHG); nonradioactive waste management; and contamination of groundwater from decommissioning activities. Therefore, this EA also provides a description of the affected environment at the FCS, considers cumulative impacts, and evaluates the impacts of climate change and GHGs, as well as nonradioactive waste management.

In the GEIS, the staff determined that a decommissioning cost assessment is not a NEPA requirement but still included a decommissioning cost evaluation (without environmental significance levels) because accurate decommissioning cost estimates are necessary for safe and timely plant decommissioning. Licensees must submit decommissioning funding plans annually. Upon receipt of a decommissioning funding plan, the NRC reviews the estimates to determine if the licensee has demonstrated compliance with 10 CFR 50.82(a)(8)(v)-(vii), thus providing assurance that the licensee is maintaining the sufficient funds for decommissioning.

2 NRC staff use a standard of significance in the GEIS, described as either SMALL, MODERATE, or LARGE. SMALL impacts are defined as environmental impacts that are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource (NRC 2002).

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2 PROPOSED ACTION AND ALTERNATIVES 2.1 Proposed Action This section discusses the history of the site and the decommissioning activities to be performed in accordance with the LTP.

2.1.1 History of the FCS License The FCS is located in Washington County, Nebraska, on the southwest bank of the Missouri River approximately 31 kilometers (km) (19 miles [mi]) north of Omaha. Figure 2. is a map showing the location of the FCS. Construction of FCS Unit 1 began in 1968, and the NRC issued an operating license to the OPPD in 1973 (OPPD 2021). The FCS began commercial operation in September 1973. The OPPD submitted the Certification of Permanent Cessation of Power Operations in August 2016 (OPPD 2016a) in accordance with 10 CFR 50.82 (a)(1)(i) and the FCS shutdown on October 24, 2016 (OPPD 2021). Pursuant to 10 CFR 50.82(a)(1)(ii), on November 13, 2016, the OPPD certified to the NRC (OPPD 2016a) that as of November 13, 2016, all fuel had been removed from the FCS reactor vessel and placed into the FCS spent fuel pool.

Pursuant to 10 CFR 50.82(a)(4)(i), the OPPD submitted its initial Post-Shutdown Decommissioning Activities Report (PSDAR) on March 30, 2017 (OPPD 2017a) and supplemented it by letter dated December 14, 2017 (OPPD 2017b) for the FCS. The PSDAR described OPPDs selection of the SAFSTOR3 method for decommissioning the FCS. The FCS reactor remained in SAFSTOR until December 16, 2019 (OPPD 2021).

On December 16, 2019 (OPPD 2019), as supplemented by letter dated July 16, 2020 (OPPD 2020a), the OPPD submitted a revised PSDAR to the NRC to reflect schedule changes and select a new method for decommissioning for the FCS pursuant to 10 CFR 50.82(a)(7). The revised PSDAR described OPPDs selection of the DECON4 method for decommissioning the FCS. The NRC staff conducted a review and found that the revised PSDAR for the FCS contained the information required by 10 CFR 50.82(a)(4)(i) (NRC 2020).

By letter dated May 18, 2020 (OPPD 2020b), the OPPD certified to the NRC that as of May 13, 2020, all spent fuel assemblies had been permanently transferred out of the FCS spent fuel pool and placed in storage within the ISFSI.

3 As defined in the GEIS Glossary, SAFSTOR is A method of decommissioning in which the nuclear facility is placed and maintained in a safe stable condition for a number of years until it is subsequently decontaminated and dismantled to levels that permit license termination. During SAFSTOR, a facility is left intact, but the fuel has been removed from the reactor vessel and radioactive liquids have been drained from systems and components and then processed. Radioactive decay occurs during SAFSTOR period, thus reducing the quantity of contaminated and radioactive material that must be disposed of during decontamination and dismantlement.

4 DECON, as defined in the GEIS Glossary, is An option for decommissioning in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

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Figure 2. FCS Unit 1 Site Location (Source: OPPD 2021)

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The OPPD submitted the LTP on August 3, 2021, in accordance with 10 CFR 50.82(a)(9). The NRC held a public meeting related to the LTP request in Blair, Nebraska, on July 13, 2022 (NRC 2022a). The meeting covered the NRCs overall decommissioning process, the process for approving the LTP, and was held to take public questions and comments on the LTP. The public asked questions regarding storage of spent fuel and future uses for the FCS site. The NRC staff and OPPD representatives responded to the questions (NRC 2022a).

2.1.2 Decommissioning Activities In 2018, the OPPD requested NRC approval to remove approximately 48.6 hectare (ha)

(120 acres [ac]) of land from the 267 ha (660 ac) Owner-Controlled Area (OPPD 2018a) and requested a separate partial site release of 192.2 ha (475 ac) in Iowa controlled by easements that formed part of the exclusion area for the plant during operations (OPPD 2018b). As part of its review, the NRC did not identify any environmental concerns associated with the release of the 48.6 ha (120 ac) and 192.2 ha (475 ac) parcels of land and determined that environmental impacts associated with the proposed release of the property were bounded by previously issued environmental impact statements, so no NEPA review was necessary (NRC 2019). The NRC approved both requests for partial site release on April 10, 2019 (NRC 2019), leaving an unreleased site area of approximately 219 ha (540 ac) (OPPD 2021; NRC 2019). Figure 3 shows the FCS site and the areas approved for partial site release.

Chapter 3 of the OPPD LTP application (OPPD 2021) identifies the completed activities as well as the remaining site dismantlement activities. The OPPD has continued dismantling and decommissioning activities as the NRC reviews the LTP.

As of July 2021, the OPPD had demolished the service building, security building, maintenance shop, technical support center, Chemistry and Radiation Protection Facility, new warehouse, and ballistic- and blast-rated enclosures (OPPD 2021). Slabs for the Technical Support Center and Chemistry and Radiation Protection Facility will be removed at a later date.

Several above-grade buildings will remain after license termination. These are the Training Building, FLEX Building, Owner-Controlled Area Entrance Building, 3451 Old Building, 3451 New Building, and 1251 Control and Switchgear Building. The switchyard will remain, but the 345 kV and 161 kV transmission lines will be removed. As mentioned above, the ISFSI and IOF will remain and were not evaluated as part of this LTP. After the reactor vessel segmentation is complete, two dry stainless-steel casks moved to the onsite ISFSI will remain under an NRC license; this is projected to occur in 2023. The Turbine Building, Containment Building, Auxiliary Building, and Intake Structure basements will remain with all interior walls removed; the turbine pedestal in the Turbine Building will remain up to 3 feet (ft) below grade. Any other onsite structures will be removed down to a minimum of 0.9 m (3 ft) below grade and undergo a final site survey for compliance with the unrestricted release criteria (OPPD 2021).

OPPD added three rail lines to the rail spur in late 2020 to allow direct loading of waste into rail cars, and these three rail lines will remain after the license is terminated to allow for final spent fuel transfer from the ISFSI to an approved permanent repository in the future. Two temporary enclosures and a dedicated haul road will be constructed to allow for removal, loading, and transporting radioactive waste to reduce cross-contamination of materials that are nonradioactive which can be disposed of at a municipal waste facility (OPPD 2021).

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Figure 3. FCS Owner-Controlled Areas (Source: OPPD 2021)

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OPPD divides the remaining decommissioning activities into several phases, which are described below (OPPD 2021):

• First Phase - Ongoing removal of nonradiological buildings (e.g., Auxiliary Building, Maintenance Building, etc.) that are currently in the deconstruction area will provide additional space for the demolition equipment and removal of radiologically contaminated buildings and components. The initial phase includes Turbine Building demolition, contaminated and noncontaminated systems removal, site building decontamination, and site remediation. All contaminated systems and components will be either decontaminated or shipped offsite to a low-level radioactive waste disposal site.

• Second Phase - Segment the reactor vessel and remove reactor internal components.

Buried piping will be removed as it becomes accessible to excavate. Removal of nonradiological buildings outside of the deconstruction area and remaining radiological buildings such as Auxiliary Building and Containment Building within the deconstruction area. The temporary waste processing structure and the portion of the rail spur within the footprint of the waste processing structure will be removed, with the rail tracks outside of the footprint remaining in place. All backfill will involve fill material from the rail spur expansion.

All debris including concrete from demolition of nonradiological structures will be removed from the site and disposed at a landfill or recycling facility.

• Subsequent Phase - The temporary waste processing enclosures and dedicated haul road that will be constructed and portions of the rail spur will be the last structures removed from the FCS site. The three rail lines that were added in late 2020 will remain in place after license termination.

• Subsequent Phase -After decontamination or removal of systems, structures and components, the comprehensive final status survey to verify that residual radioactivity has been reduced according to 10 CFR 20.1402 will be performed to demonstrate that the FCS can be released for unrestricted use.

The NRC will not terminate the FCS license until the OPPD demonstrates in its final radiation survey that the site meets the 10 CFR 20.1402 criteria and that the facility has been dismantled in accordance with the approved LTP. The OPPD anticipates completing decommissioning by the end of 2025, after which it will complete the final status survey. Finally, the OPPD estimates license termination in early 2026 (OPPD 2021). Detailed schedules for significant decommissioning activities, including the final site survey, will be routinely communicated to NRC headquarters and NRC Region IV personnel to allow for NRC observation and inspection of these activities. After decommissioning activities are completed and the NRC operating license terminated (except for the ISFSI), the OPPD plans to release the site for unrestricted use, except for the ISFSI, as pictured in figure 3.

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2.2 Alternatives As discussed as an alternative to the proposed action in section 1.3 of this EA, the NRC staff considered the no-action alternative. Under the no-action alternative, the NRC would not approve the LTP or the license amendment request because regulatory requirements have not been met. If the NRC was unable to approve the LTP because the regulatory requirements were not met, the OPPD would need to take additional action to prepare an LTP that meets the requirements in 10 CFR 50.82(a)(10). Under this scenario, the OPPD resubmits the LTP, activities at FCS would likely continue and the environmental impacts would neither increase nor decrease as a result of the additional time required for the LTP resubmission. As such, the no-action alternative is not evaluated in further detail.

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3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS This section describes both the current environmental conditions at the FCS site to provide a framework, or baseline, for the evaluation of the potential environmental impacts. It also describes the environmental impacts on those resources that may be affected by the proposed action.

Table 1 lists impacts from environmental resource areas that are generically resolved and bounded by the GEIS. This EA will focus on those areas that were not generically resolved in the Decommissioning GEIS and therefore require site-specific analysis of potential impacts in resource areas that were not addressed in the GEIS. As discussed in section 1.4, these impacts requiring site-specific analysis are:

• Offsite land use

• Threatened and endangered species

• Aquatic ecology beyond the operational area

• Terrestrial ecology beyond the operational area

• Environmental justice

• Historic and cultural resources beyond the operational area Areas that were not addressed in the GEIS but will be addressed in this EA are:

• Affected environment at the FCS

• Climate change and GHGs

• Nonradioactive waste management

• Groundwater contamination as the result of decommissioning

• Cumulative impacts Table 1. Environmental Resource Areas Bounded by the Decommissioning GEIS Environmental Resource Impact Considerations Land Use The NRC staff expects no impacts associated with these issues beyond those discussed in the GEIS, which concluded that the impact level is SMALL. However, offsite, the GEIS notes that potential impacts may be SMALL, MODERATE, or LARGE and must be determined through site-specific analysis.

Aesthetics/Noise The NRC staff expects no impacts associated with these issues beyond those discussed in the GEIS, which concluded that the impact level is SMALL. Activities will include restoring the site to a more natural grade and allowing broader views of the Missouri River once the site is returned to open space. Noise will be generated primarily from typical decommissioning and demolition activities and heavy equipment use.

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Environmental Resource Impact Considerations Air Quality The NRC staff expects no impacts associated with these issues beyond those discussed in the GEIS, which concluded that the impact level is SMALL. Air emissions such as exhaust and fugitive dust will be localized and temporary. The OPPD will comply with all applicable State and Federal regulations related to air emissions.

Water Use and Quality The NRC staff expects no impacts on water use or quality other than those described in the GEIS. The GEIS concluded the impacts on water quality for both surface water and groundwater indicate that for all facilities the impacts of decommissioning will be neither detectable nor destabilizing and therefore SMALL. Groundwater protection programs and environmental monitoring programs will continue to monitor the resources during decommissioning.

Historic and Cultural Resources Within the operational area, the NRC staff expects no impacts to historic and cultural resources beyond those discussed in the GEIS, which concluded that the impact level is SMALL. However, outside of the operational area, the GEIS notes that potential impacts may be SMALL, MODERATE, or LARGE, and must be determined through a site-specific analysis.

Aquatic and Terrestrial Ecology Within the operational area, the NRC staff expect no impacts to within the Operational Area ecology beyond those discussed in the GEIS, which concluded that the impact level is SMALL. However, outside of the operational area, the GEIS notes that potential impacts may be SMALL, MODERATE, or LARGE and must be determined through a site-specific analysis.

Socioeconomics The NRC staff expects no socioeconomic impacts beyond those discussed in the GEIS, which concluded that the impact level is SMALL. Site-specific information included as part of the license termination plan was provided for the affected environment and as a baseline for the other resource evaluations.

Public and Occupational Health The NRC staff expects no impacts associated with public or occupational health beyond those discussed in the GEIS, which concluded that the impact level is SMALL. The estimated total radioactive exposure is 230 person-rem, which is well below the GEIS estimated exposure of 560 person-rem. To ensure this, as well as compliance with all NRC regulatory limits, the OPPD will continue to operate the Radiological Groundwater Protection Program (RGPP) and Radiological Environmental Monitoring Program (REMP).

Transportation The NRC staff does not expect impacts associated with transportation to be destabilizing or beyond those discussed in the GEIS, which concluded that the impact level is SMALL 3.1 Land Use 3.1.1 Land Use including Site Description and Vicinity Before a 2019 partial site release described below, the FCS site consisted of approximately 267 ha (660 ac) owned by the OPPD on the Missouri River at river mile 646.0, approximately 31 km (19 mi) north of Omaha, Nebraska (OPPD 2021). It is situated in an unincorporated area of Washington County, Nebraska, where there are no land-use or zoning restrictions (NRC 2003). Prior to the 2019 partial site release, the OPPD also held perpetual easements on an additional 244 ha (604 ac) of cropland and natural vegetation north of the site across the Missouri River in Harrison County, Iowa (NRC 2003). In 2019, NRC approved a request from December 2023 3-2

the OPPD to release approximately 48.6 ha (120 ac) of undeveloped land from the FCS site, as well as the release of the easements in Iowa, leaving an unreleased site area of approximately 219 ha (540 ac) (OPPD 2021; NRC 2019).

Approximately 55 ha (135 ac) of the remaining 219 ha (540 ac) 267 ha (660 ac) at the FCS site is occupied by plant facilities or is maintained as part of plant operation (NRC 2003). Principal structures on the FCS site include the Containment Building (which includes the reactor and nuclear steam supply system), Auxiliary Building, Turbine Building, Service Building, intake structure on the south bank of the Missouri River, Security Access Facility, Switchyard, Administration Building, Training Center, Radioactive Waste Processing Building, Chemistry and Radiation Protection Building, and warehouse (OPPD 2017a). As depicted in figure 3, the OPPD constructed an ISFSI, which holds spent fuel generated during the FCS operations, on approximately 2.6 ha (6.5 ac) in the northwest part of the developed area of the FCS site (OPPD 2021). The OPPD does not plan to decommission the ISFSI at this time but instead plans to maintain it under the 10 CFR Part 72 general license associated with its 10 CFR Part 50 license from NRC (OPPD 2021).

Approximately 140 ha (345 ac) of the FCS site is cropland that the OPPD leases to local farmers, and approximately 73 ha (180 ac) contains natural vegetation, drainage courses, and a railroad spur (NRC 2003). As is evident from the aerial photography in figure 3, most of the natural vegetation on the FCS site, including the forest and wetlands, is situated in a band of lower-lying lands on the banks of the Missouri River, while most undeveloped land on the FCS site away from the river is in agricultural use.

The FCS site is situated in a predominantly agricultural area north of the Omaha metropolitan area (OPPD 2021). The FCS site is bordered to the northwest by an industrial facility (Cargill Industries) and farm fields, to the southeast by farm fields, to the south by a state highway along which residences are located, and to the north by the Missouri River, farm fields, and a wildlife refuge (OPPD 2021). Aerial photography used in figure 4 indicates that the land directly across the Missouri River from the FCS site is used either for agricultural purposes or is naturally vegetated land. The DeSoto National Wildlife River is situated approximately 1.6 km (1 mi) east of the FCS site.

3.1.2 Land-Use Direct and Indirect Impacts Decommissioning GEIS Determination The GEIS concludes generically that the potential land-use impacts from decommissioning activities on a nuclear plant site are SMALL, although it indicates that a site-specific analysis is necessary to determine the significance of offsite land-use impacts (NRC 2002). Therefore, as noted above, the GEIS bounds the onsite land-use impacts for the FCS. This means, in accordance with the conclusion in the GEIS, those impacts will be SMALL.

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Figure 4. FCS End State (Source: OPPD 2021)

Site-Specific Activities In its 2017 PSDAR, the OPPD states that the FCS contains enough previously disturbed land to provide enough area for decommissioning use (OPPD 2017a). In its 2021 LTP application, the OPPD states that the decommissioning project would be executed within FCS lands retained by the OPPD for plant-related use following the land releases approved by the NRC in 2019 (OPPD 2021). The OPPD explains that only lands within the FCS site would be used to support December 2023 3-4

decommissioning and license termination activities such as development and use of temporary storage and staging areas, and that the OPPD would institute appropriate isolation and control measures and monitoring to prevent the spread of contamination (OPPD 2021). The OPPD indicates that land disturbance would not be conducted in environmentally sensitive lands, such as wetlands, on the site or where the site adjoins environmentally sensitive offsite lands, and that the OPPD would put best management practices (BMPs) in place to minimize the potential for sediment and erosion discharges before initiating land-disturbing activities (OPPD 2021).

Based on the generic determination in the GEIS regarding the SMALL significance of decommissioning activities on the licensees onsite land use, and on OPPDs plan to limit land disturbance from decommissioning and license termination activities to onsite land acreage and commitment to use BMPs to protect adjoining offsite lands, the NRC staff concludes that the offsite land-use impacts would be minimal.

3.2 Visual and Scenic Resources/Aesthetics 3.2.1 Description of the Visual and Scenic Affected Environment About 85 percent of the FCS site is on relatively level ground on the river bottomlands, with the southern portion of the site rising sharply by approximately 18 m (60 ft) to U.S. Highway 75 (NRC 2003). The FCS and its supporting structures can be seen from the immediate surrounding area, from U.S. Highway 75, and by recreational users on the Missouri River (NRC 2003). However, the most visible structures (e.g., auxiliary buildings, the containment structure) are the same ones that the OPPD will remove for decommissioning. The ISFSI, which will remain after decommissioning, is several hundred meters (yards) from the Missouri River (OPPD 2021).

3.2.2 Visual and Scenic Resources Direct and Indirect Impacts Decommissioning GEIS Determination Temporary (e.g., noise and dust) and permanent (e.g., viewsheds) aesthetic impacts will result from decommissioning. Licensees are expected to use BMPs to control dust and noise. The removal of structures is generally considered beneficial to aesthetics (NRC 2002). The GEIS states that aesthetic impacts could improve rapidly for the DECON method of decommissioning if the licensee dismantles the facility, removes the structures, and regrades the site before license termination (NRC 2002). The NRC staff expects no aesthetic impacts beyond those discussed in the GEIS, which concluded that for all types of nuclear power plants, the impacts on aesthetics are SMALL and mitigation is not warranted.

Site-Specific Activities Once the major FCS structures located along the banks of the Missouri River are removed for decommissioning, there will be a more open view of the river. The OPPD plans to restore the site to a more natural grade, thus allowing broader views of the Missouri River once the site is returned to open space (OPPD 2021).

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3.3 Climatology, Meteorology, and Air Quality 3.3.1 Climatology and Meteorology Washington County, Nebraska, is situated between the humid east climate zone and the dry west climate zone. The FCS site experiences weather from both zones, and there are rapid weather changes, especially in winter due to the FCS location between these zones. The mean annual temperature for the region is 51.1°F (10.6°C), with a January monthly mean of 20.2°F

(-6.6°C) and July monthly mean of 77.7°F (25.4°C) (OPPD 2021). The region experiences an average of 78 percent relative humidity from midnight to noontime and 59 percent from noontime to midnight (OPPD 2021).

Annual average precipitation varies widely from year to year. The annual average precipitation for the region is approximately 76 centimeters (cm) (30 inches [in.]) with most of the precipitation due to showers and thunderstorms between April and September (OPPD 2021).

The annual snowfall amount also varies widely but is approximately 76 cm (30 in.) of snow per year in the region. Prevailing winds in the region are from the south-southeast from May to December and from the north-northwest during the rest of the year, with a mean annual wind speed of 17.1 kilometers per hour (10.6 miles per hour). There have been tornadoes reported in surrounding counties but no reported damage from tornadoes within 8 km (5 mi) of the FCS.

Since 1950, there have been 19 tornadoes reported in Washington County, Nebraska; 20 reported in Douglas County, Nebraska; 42 reported in Pottawattamie County, Iowa; and 23 reported in Harrison County, Iowa (OPPD 2021).

3.3.2 Air Quality Washington County, Nebraska, is classified as in attainment of all National Ambient Air Quality Standards per 40 CFR Part 81 (EPA 2022). The OPPD currently has an Air Quality Construction Permit from the Nebraska Department of Environment and Energy to regulate air emission sources at the FCS (OPPD 2019). This air permit will remain in effect during decommissioning and will be modified if new sources of air emissions are added or changed at the facility. The OPPD anticipates emissions from worker vehicle traffic, although the number of employees has been reduced from about 700 OPPD employees since the FCS stopped operations to approximately 335 employees and contractors performing deconstruction activities in 2022 (OPPD 2022). The workforce will decline each year from 2023 (approximately 125 staff) until the conclusion of decommissioning in 2026 (less than 40 staff), and emissions from vehicle traffic will be further reduced.

3.3.3 Greenhouse Gases and Climate Change In CLI-09-21 (NRC 2009), the Commission provided guidance to the NRC staff on addressing GHG issues in environmental reviews. That guidance directed the NRC staff to include consideration of carbon dioxide and other greenhouse gas emissions in its environmental reviews for major licensing actions under the National Environmental Policy Act. This Commission decision was issued after the GEIS was finalized in 2002, and as such, these topics were not addressed in the GEIS.

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Decommissioning activities include vehicle traffic, demolition of structures, dismantlement and decontamination of systems, and movement of materials onsite and shipment offsite occurring over a period from 2019 until decommissioning is complete. Equipment, worker vehicles, and truck shipments associated with decommissioning activities emit criteria pollutants and GHGs.

The NRC developed a generic GHG footprint for the life cycle of a reference 1,000-MWe light-water reactor with an 80 percent capacity factor, for a net electric output of 800 MW(e) (NRC 2014). The life cycle footprint includes decommissioning. The generic GHG footprint can be scaled for the number of units and electrical capacity. The FCS has one unit that is much smaller in size (484 MWe) and has an estimated capacity factor of 90 percent. For the generic GHG footprint, decommissioning over a 10-year period results in an estimated 19,000 MT carbon dioxide equivalents (CO2e) from decommissioning equipment and another 8,000 MT CO2e from the decommissioning workforce (NRC 2014). For FCS, this amounts to 14,702 MT CO2e over a 10-year period (27,000 MT CO2e scaled to 90 percent capacity and 484 MWe, divided by 800 MWe for reference reactor).

In 2018 the U.S. Global Change Research Program (GCRP) published its most recent report regarding the state of climate change in the nation (GCRP 2018). The FCS site is located on the boundary of two geographic areas defined in the GCRP report, the Northern Great Plains, and the Midwest. The GCRP characterizes the Northern Great Plains as having an increased growing season length and greater variability in temperature and precipitation, which stress critically important natural resources. The impacts of climate change throughout the Northern Great Plains include changes in flooding and drought occurrences, rising temperatures, and the spread of invasive species. The area where the FCS site is located is prone to flooding, warmer temperatures, and the potential for more extreme rainfall events all as a result of climate change (GCRP 2018).

For Nebraska, the GCRP report predicts an increase in the number of days above 90°F (32°C),

with potential impacts on agriculture, energy production, human health, streamflow, snowmelt, and fires. The GCRP predicts a decrease in the number of days below 28°F (-2.2°C), with impacts on the regions snowpack and streamflow and water use, and an increase in the number of days with over 1 in. of precipitation for the middle of the 21st century (2036-2065) as compared to the 1976-2005 average (GCRP 2018). There is a large degree of year-to-year variability in precipitation and streamflow projections for both wet and dry years. Because of this variability, there are low-probability but high-severity and high-impact events in the region, including both extreme flood events and drought events such as occurred in 2011 and 2012, respectively (GCRP 2018). A 2011 flooding event at the FCS was attributed to near-record snowfall totals and record-setting rains in late May and early June. This year-to-year variability in precipitation and streamflow implies greater uncertainty about future climate and about the potential for future flooding and drought (GCRP 2018).

Agriculture production in the area has benefited from longer growing seasons, but rising temperatures and changes in extreme weather events are likely to negatively impact agriculture in parts of the region. For the Northern Great Plains region, there are also recreational impacts from climate change, such as shorter snow seasons that impact winter recreational activities and reduced streamflow and rising temperatures that impact river-based recreational activities.

3.3.4 Direct and Indirect Impacts Decommissioning GEIS Determination December 2023 3-7

In section 4.3.4, the GEIS lists several activities that could impact air quality during decommissioning. Decommissioning activities include vehicle traffic, demolition of structures, dismantlement and decontamination of systems, and movement of materials onsite and shipment offsite occurring until decommissioning is complete. The GEIS concluded that impacts on air quality from decommissioning are SMALL. The staff expects no impacts on air quality other than those described in the GEIS (NRC 2002).

Site-Specific Activities For the DECON option, the OPPD does not anticipate any activities beyond those listed in the GEIS that could potentially affect air quality (OPPD 2021). Equipment, worker vehicles, and truck shipments emit criteria pollutants and GHGs. Structure demolition and dismantlement and truck traffic cause fugitive dust emissions. Emissions from decommissioning are localized and temporary. Equipment and processes onsite may be subject to State, such as Nebraskas Fugitive Dust Title 129 Chapter 15 Section 003, regulations which cover demolition and decommissioning activities (State of Nebraska 2023). Air emissions such as vehicle and equipment exhaust and fugitive dust will be monitored during decommissioning activities and continue to be monitored in the current air monitoring program (OPPD 2021). Both the amount of worker vehicle traffic and truck traffic will be lower than when the FCS was in operation. The OPPD will comply with all applicable Federal and State regulations related to air emissions and will implement BMPs to minimize particulate matter and fugitive dust during demolition and decommissioning (OPPD 2021).

With regard to GHGs, as mentioned above, for decommissioning the FCS over a 10-year period, the NRC staff expects decommissioning equipment and the decommissioning workforce to emit 14,702 MT CO2e. The OPPD began DECON in 2020 and expects to complete decommissioning in 2025, so the 10-year estimate is bounding for the FCS because the annual emissions would occur for fewer years. Total emissions of 14,702 MT CO2e over a 10-year period amounts to 1,470 MT CO2e annually. Under 40 CFR Part 98, facilities must report emissions annually to the Environmental Protection Agency (EPA) if they emit 25,000 MT or more per year of CO2e. The 1,470 MT CO2e expected from the FCS annually is far below the EPAs reporting threshold. Given that GHG emissions during decommissioning would be localized and temporary and well below the EPA-GHG-reporting threshold, the NRC staff concludes that the proposed actions impact on GHG would be minimal.

Even though GHG emission estimates from decommissioning are far below the EPA-GHG-reporting threshold, the licensee could consider measures that would reduce GHG emissions.

These could include use of low-GHG-emitting vehicles and other policies to reduce GHG emissions from vehicle use (e.g., anti-idling policies, vanpooling, or carpooling). Maintenance of on-road construction vehicles and off-road construction equipment would also minimize daily GHG emissions.

As discussed above, climate change may lead to flooding and warmer temperatures, and increase the potential for more extreme rainfall events in the region. That said, there is also year-to-year variability in the impacts of climate change regarding precipitation and streamflow (GCRP 2018). Decommissioning the FCS will have minimal impact on surface water use and quality, as discussed in section 3.6.1 of this EA, such that the FCS decommissioning would not contribute to further impacts on the Missouri River when combined with the impact of climate change causing either an increase or decrease in river flow. In a higher temperature environment, the formation of ozone due to emissions of nitrogen oxides from onsite equipment may increase. However, air emissions due to decommissioning activities are localized and December 2023 3-8

temporary and unlikely to contribute measurably to ozone formation. The thermal impact to the Missouri River from the FCS is no longer present given that operations have ceased, therefore increasing river water temperatures resulting from increasing air temperatures would not be exacerbated by decommissioning activities. Therefore, when the impact of the proposed action is combined with the impacts of climate change, the proposed action has minimal impacts on the relevant environmental resources.

3.4 Noise 3.4.1 Noise Levels The FCS is located on the Missouri River, and there are no residences within 0. 8 km (0.5 mi) of the site. There are no schools, hospitals, prisons, motels, or hotels in the immediate vicinity of the site. The nearest community is Blair, Nebraska, located approximately 4.8 km (3 mi) to the northwest of the site. Therefore, given the location, noise receptors are minimal.

3.4.2 Noise Direct and Indirect Impacts Decommissioning GEIS Determination Noise will be generated primarily from demolition activities and heavy equipment. Rail and truck shipments also would generate noise. The ISFSI is a passive facility, and there will be only minimal noise from its operation. Most other license termination activities (e.g., site radiological surveys and scans) would not generate noise. Because of the distance of the FCS from the nearest community, there would be no noise impacts experienced by sensitive receptors according to the GEIS (NRC 2002). The staff expects no impacts on noise other than those described in the GEIS. The GEIS concluded that impacts on noise from decommissioning are SMALL.

Site-Specific Activities Noise from the shipment of waste would be minimal because shipment is primarily by rail, and rail shipments from the FCS would be a small fraction of the normal rail transport volume (OPPD 2022). Noise associated with decommissioning and shipment of waste is intermittent and temporary (OPPD 2021).

3.5 Geology and Soils 3.5.1 Regional and Site-Specific Geology The FCS site is in a geologic environment made of thick beds of limestone, dolomite, shale, sandstone, and coal beds in thin layers (OPPD 2021). Most of the important features of the Nebraska-Iowa Missouri River Valley area started to develop at the end of the Permian period with no record of fault movement in the past or in recent time periods (OPPD 2021). Most of the Missouri River Valley and tributaries to the river were formed during the Pleistocene period, and during glacial movements, the valleys in the region were periodically opened and then filled.

This resulted in the terraces and adjacent uplands being covered in Peorian loess. Soils at the site consist of an upper fine-grained sandy clay with silt 6 to 15 m (20 to 50 ft) thick that is likely not continuous as it is indicative of former river deposits and an underlying carbonate bedrock surface sitting 20 to 23 m (65 to 75 ft) below ground level (OPPD 2021).

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The FCS site region has infrequent seismic activity. Within 322 km (200 mi) of the plant site there have been 13 seismic occurrences with Modified Mercalli Intensity (MMI) scale V intensities, and only one earthquake with a MMI scale of VI intensity, which occurred in 1935 near the town of Tecumseh, Nebraska (OPPD 2021). The MMI scale measures shaking intensity of an earthquake, with values of MMI VI and above resulting in building damage.

3.5.2 Regional, Site-Specific Geology and Soils Direct and Indirect Impacts Decommissioning GEIS Determination The Decommissioning GEIS did not include geology as resource area because current power plants locations span a number of geologic settings, and any new power plant would have its site-specific geologic conditions evaluated as part of the licensing application. Therefore, this resource area was not evaluated in the GEIS (NRC 2002) but is included in this EA to characterize the affected environment.

Site-Specific Activities Decommissioning activities would not impact the geology, soils, or seismicity at the site because decommissioning activities do not require alternations to the regional or site geology. Further, the site location is already disturbed due to previous construction and operation, and all impacts are expected to be less than those of construction as evaluated in the Final Environmental Statement (OPPD 1971). Additional information on the soil contamination associated with decommissioning activities can be found in section 3.10.2.

3.6 Water Resources 3.6.1 Surface Water 3.6.1.1 Surface Water Use and Quality The FCS site is bordered to the north by the Blair Bend of the Missouri River, which was the FCSs main source of cooling water during operations and is commonly used for commercial barge and recreational boat traffic. The Missouri River is highly modified and controlled for most of its length because of numerous U.S. Army Corps of Engineers actions to prevent meandering within the alluvial flood plain (OPPD 2021). Gavins Point Dam is the nearest structure to the FCS. Six dams located upstream of the FCS site control river flow, and no dams, locks or similar structures are located downstream of the site. Wetlands and surface streams exist near the FCS site, including Fish Creek, which runs along the west side of the ISFSI and switchyard as well as Long Creek, which is approximately 1.1 km (0.7 mi) southeast and DeSoto Lake, which is 2.9 km (1.8 mi) east (OPPD 2021).

The Missouri River serves as a source of extensive municipal and domestic water supplies, with multiple potable intakes located near the FCS. The closest potable water intakes are about 1.6 km (1 mi) northwest of the site upstream and 32 km (20 mi) downstream (OPPD 2021).

The OPPD has a general National Pollutant Discharge Elimination System (NPDES) permit for stormwater discharges and a general NPDES permit for dewatering discharges. These permits allow for nonradiological water discharges to Fish Creek and the Missouri River and will no longer be needed once decommissioning is complete (OPPD 2019). The IOF sewage system does not discharge to the environment, and the training center onsite will have a new onsite December 2023 3-10

sewage system. The OPPD implements BMPs for soil erosion and sedimentation control (OPPD 2021).

The FCS site has experienced several floods. The most recent flooding event was in 2019, and the largest flood was in 2011 when the Missouri River overflowed the riverbanks (figure 5). The FCS site was flooded for approximately 3 months, including the sanitary lagoons onsite. The OPPD had installed aqua-berms and raised walkways in advance of the flooding to protect the facility. In 2013, after NRC oversight and flood recovery, the FCS returned to operations. To mitigate flood impacts during decommissioning, the OPPD installed a HESCO barrier in 2020 around the FCS site shown in figure 6. The barriers range 1.5-3.0 m (5-10 ft) in height, run approximately 2,438 m (8,000 ft) and are comprised of sand and gravel-filled fabric-lined cages (OPPD 2021). The OPPD will likely remove this HESCO barrier after decommissioning activities are complete.

Figure 5. Extent of 2011 Flooding Event (Source: OPPD 2021)

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Figure 6. Location of HESCO Flood Barrier (Source: OPPD 2021) 3.6.1.2 Surface Water Direct and Indirect Impacts Decommissioning GEIS Determination The GEIS states that water use dramatically decreases after plants cease operations and that the quantities of water required during decommissioning for dust abatement or spent fuel cooling are trivial compared to the quantity used during operations (NRC 2002). The GEIS also states that stormwater runoff and erosion control are expected to be managed with BMPs to minimize surface water quality changes to nondetectable levels and that any hazardous spills onsite are localized, quickly detected, and relatively easy to remediate for decommissioning sites (NRC 2002). The GEIS concluded that impacts on surface water use and quality from decommissioning are SMALL. The staff expects no impacts on surface water use or quality other than those described in the GEIS.

Site-Specific Activities Water use during decommissioning is significantly less than during operations because the Missouri River is no longer used as cooling water for the reactor systems and is only used for dilution of released liquid waste, which will be processed according to the NPDES permits (OPPD 2021). Further, because the Missouri River is no longer used as cooling water, thermal December 2023 3-12

impacts to the Missouri River were reduced after operations ceased. Potable water use during decommissioning is estimated to be less than during operations.

The OPPD will comply with all Federal, State, and local permits pertaining to water quality throughout decommissioning activities. Additional construction and NPDES permits will be obtained to regulate surface water discharges from the FCS site to avoid and/or minimize impacts to water quality (OPPD 2019). The additional inclusion of other applicable Federal, State, and local water quality permits ensures that surface water impacts are either minimal or evaluated in an appropriate environmental review.

During decommissioning, the FCS site will use potable water from the City of Blair to serve the remaining buildings onsite and for use in decommissioning activities (OPPD 2019). The amount of potable water during decommissioning is expected to be less than used during operation of the FCS. The FCS Unit 1 supplemental environmental impact statement (SEIS) states the FCS uses approximately 38 million liters (L) (10 million gallons [gal]) per month of filtered, chlorinated water from the City of Blair Municipal Water System for potable water, service water, and other uses (NRC 2003).

3.6.2 Groundwater 3.6.2.1 Groundwater Use and Quality Groundwater gradients at the FCS site are nearly flat, gently sloping toward the Missouri River about 3 m (10 ft) below ground, and the groundwater is hydraulically connected to the river.

Groundwater levels vary from 302.8 m (993.7 ft) to 302.5 m (992.4 ft) in elevation at the site, while river levels range from 302.7 m to 302.5 m (993.2 ft to 992.4 ft) during the same time period (OPPD 2021). Groundwater levels vary with changes in river level, and the groundwater flow rate is slow due to the low gradient (OPPD 2021). Groundwater flow occurs toward the river when Missouri River levels are lower in spring, summer, and early fall, and away from the river when levels are higher during late fall and winter (OPPD 2021).

A reverse osmosis water treatment plant on the FCS site withdrew groundwater to be used for FCS operations. The use of this plant caused a cone of depression and altered groundwater flow (OPPD 2021). The extraction well, operated from 2007 to 2018, was located in the northwest corner of the old warehouse slab onsite, and continuously pumped 757 liters per minute (200 gallons per minute) (OPPD 2021). Groundwater flow measurements indicated flow in the southwest direction toward the extraction well.

There are 31 active private wells for domestic use and 13 irrigation wells within 4.0 km (2.5 mi) upstream and 7.2 km (4.5 mi) downstream from the FCS (OPPD 2021). Several additional wells in this area are used for public water supply for recreational areas, environmental monitoring, and commercial or industrial operations. Groundwater is not used for drinking at the FCS or within 0.8 km (0.5 mi).

3.6.2.2 Groundwater Direct and Indirect Impacts Decommissioning GEIS Determination As discussed in the Decommissioning GEIS, the impact of nuclear reactor facilities on water resources dramatically decreases after operation of the plants cease. However, water could still be required for activities including fuel removal, staff changes, large component removal, and decontamination and dismantlement. This demand would decrease over time as the December 2023 3-13

decommissioning process progresses. In addition, as the plant staff decreases, the demand for potable water also generally decreases. However, in a few cases staffing levels have temporarily increased above levels that were common for routine operations. For these short periods of time, typically during the early stages of decontamination and dismantlement activities, there may be a slight increase in demand for potable water. The GEIS concluded the impacts on water quality for both surface water and groundwater indicate that for all facilities, the impacts of decommissioning would be neither detectable nor destabilizing and therefore SMALL, and additional mitigation is not warranted (NRC 2002).

Site-Specific Activities Impacts to groundwater are monitored through routine sampling. The FCS site currently has a RGPP in accordance with the Nuclear Energy Institute Technical Report 07-07, Industry Groundwater Protection Initiative - Final Guidance Document, Rev. 0 (NEI 2007), which the NRC staff has endorsed. This program, along with the Offsite Dose Calculation Manual (ODCM) and REMP, will continue during decommissioning to protect groundwater (OPPD 2019). The RGPP and the REMP are used to assess radiological impacts on the groundwater and monitor adherence to the ODCM (OPPD 2021). Twenty-three permanent RGPP wells on the FCS site are routinely sampled along with other groundwater locations on the site to verify adherence to the limits set for offsite doses.

Neither the monitoring results of the RGPP nor records kept for events noted in 10 CFR 50.75(g), such as records of spills or unusual occurrences, indicate the presence of long-lived radionuclides in sufficient concentrations to preclude unrestricted release under 10 CFR 20.1402, Radiological criteria for unrestricted use (OPPD 2019). However, as discussed further in the NRCs consultation letter to the EPA (NRC 2023a), the OPPD has sampled onsite monitoring wells as part of an ongoing groundwater monitoring program. The NRC has determined that the licensees proposed dose conversion factors for groundwater could potentially lead to concentrations that exceed the EPA Maximum Contaminant Levels (MCL) concentrations, which triggers Level 1 consultation under a 2002 NRC-EPA memorandum of understanding for groundwater. Therefore, the NRC has requested a Level 1 consultation for groundwater.

As further discussed in the above-mentioned consultation letter, sample results from groundwater monitoring wells have detected tritium and strontium-90 concentrations that are above the detection limits but well below the MCLs for these radionuclides. Based on this historical groundwater monitoring performed at the site, the NRC does not expect the measured groundwater concentrations during the final site survey to exceed the EPA MCLs. However, once the OPPD completes decommissioning, if the residual activity is greater than the EPAs standards, the EPA can decide if it will require further action by the licensee. However, the NRC would still be able to terminate the license if the NRC release criteria are met. Therefore, the staff anticipate no additional impacts on groundwater use or quality other than those described in the GEIS.

3.7 Historic and Cultural Resources 3.7.1 Historic and Cultural Resources Affected Environment The National Historic Preservation Act of 1966, as amended (the act), requires Federal agencies to consider the effects of their undertakings on historic properties, and the remaining decommissioning activities and license termination activities at the FCS are an undertaking that December 2023 3-14

could potentially affect historic properties. As stated in the act, historic properties are any prehistoric or historic district, site, building, structure, or object included in, or eligible for, inclusion in the National Register of Historic Places.

During the review of the FCS for the SEIS, the staff reviewed historic characteristics of the property by searching the Nebraska State Historic Preservation Office (Ne SHPO) files and information provided by the OPPD. Based on that review, the NRC identified the section of the plant site that lies north of the rail spur and is bounded on the west by U.S. Highway 75 as having Moderate-to-High Potential for historic or cultural resources. It contains remnants of the former town of De Soto, a historic property that is eligible for listing as a historical place (Ne SHPO 2020). The area to the south of the current Union Pacific rail spur, which is located offsite, has been impacted by past construction activities, has been developed since 1850, and lies on floodplain alluvium. Due to these ground-disturbing activities around the FCS site, there are likely no potential for cultural resources (OPPD 2021).

In 2013, the Nebraska State Historical Society (NSHS) performed archaeological testing to determine if a proposed Nebraska Department of Roads project that was planned within the site boundary for the De Soto Townsite would have an adverse impact on the townsite archaeological site. The portions of De Soto townsite located within the FCS site boundary, were, in part, disturbed by the FCS construction activities. The NSHS performed fieldwork and testing at the De Soto Townsite and found that there were no intact cultural layers in the area surveyed, which was on the FCS site, and the artifacts recovered could not be positively attributed to the town of De Soto (OPPD 2022). The NSHS concluded that the Department of Roads project would not affect significant archaeological deposits and recommended a finding of no historic properties affected to Ne SHPO (OPPD 2022). Therefore, implementation of this project did not impact historical properties.

Because the FCS has existed for more than 50 years, the NRC staff requested that the OPPD consult with the Ne SHPO to determine if the FCS itself could be considered an eligible historic property (NRC 2022b). The OPPD confirmed that Ne SHPO does not consider the FCS to be a historic property (OPPD 2022).

There are no decommissioning activities planned to occur on previously undisturbed land at the FCS site and surroundings (OPPD 2022). However, the OPPD has processes in place to mitigate impacts if decommissioning activities necessitate disturbing previously undisturbed areas. These mitigation measures are discussed in the following section.

The NRC staff also contacted 12 Federally recognized Tribes that have historic or current ties to the FCS project area to assist in identifying historic and cultural properties within the FCS site boundary. Those activities are further discussed in section 4.2.

Also noted in section 4.2, in June 2022, Ne SHPO reviewed the proposed LTP and determined that no historic properties would be affected by the decommissioning of the FCS (OPPD 2022).

3.7.2 Historic and Cultural Resources Direct and Indirect Impacts Decommissioning GEIS Determination As discussed in the Decommissioning GEIS, 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. Usually, the areas disturbed, or used to support decommissioning are within the December 2023 3-15

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 be SMALL. The staff does not anticipate any impacts beyond those discussed in the GEIS.

Site-Specific Activities Although the Decommissioning GEIS concluded a site-specific inquiry was necessary outside the operational area, there are no decommissioning activities planned to occur on previously undisturbed land at the FCS site and surroundings (OPPD 2022). The PSDAR discusses mitigation measures that are still in place regarding ground-disturbing activities in previously undisturbed areas. These mitigation measures include:

1. Decommissioning activities will be primarily contained to disturbed areas located away from areas of existing or high potential for archaeological sites.

2. An NPDES Construction Storm Water General Permit is required for construction activities that disturb 0.4 ha (1 ac) or greater of soil by the Nebraska Department of Environment and Energy approval. This permit would require BMPs (e.g., soil stockpiling) to control sediment and the effects of erosion.

3. Environmental protection procedures pertaining to archaeological and cultural resources will remain in effect during decommissioning (OPPD 2019).

Based on the decommissioning activities being planned for previously disturbed areas (e.g.,

De Soto Road Project), the mitigation measures in place should activities be necessary in previously undisturbed areas, and the Ne SHPO determination that no historic properties would be affected by the decommissioning of the FCS, the NRC staff determines that there would be no impacts on historic properties from the proposed action. The NRC staff sent its determination to the Ne SHPO on September 29, 2022 (NRC 2022c). The Ne SHPO responded on September 30, 2022, with its concurrence that no historic properties will be affected by the undertaking (Ne SHPO 2022).

3.8 Ecological Resources 3.8.1 Terrestrial Resources As described in the FCS Unit 1 SEIS, approximately 75 percent of the original 267 ha (660 ac)

FCS site consisted of agricultural land, station facilities, and other developed land, and the remaining 25 percent consisted of natural vegetation such as upland forest, floodplain forest, and wetlands (NRC 2003). The upland forest was described in the SEIS as dominated by black locust (Robinia pseudoacacia), red mulberry (Morus rubra), Siberian elm (Ulmus pumila), and hackberry (Celtis occidentalis), with abundant poison ivy (Toxicodendron spp.) and stinging nettle (Urtica dioica) in the understory. According to the SEIS, the floodplain forest borders the Missouri River, North and South Sloughs, and Long Creek and is dominated by green ash (Fraxinus pennsylvanica), cottonwood (Populus spp.), box elder (Acer negundo), silver maple (Acer saccharinum), and hackberry, with an understory of false indigo (Baptisia spp.), rough dogwood (Cornus drummondii), giant ragweed (Ambrodia trifida), goldenrod (Solidago spp.),

and milkweed (Ascepias spp.). All of the tree species identified as dominant in the upland and floodplain forests in the SEIS are deciduous, losing their leaves in the fall and regrowing them in the spring. According to the SEIS, the wetlands comprise less than 5 percent of the FCS lands December 2023 3-16

and included narrow-leaved cattail (Typha angustifolia), reed canary grass (Phalaris arundinacea), sedges (Carex spp.), rushes (Juncus spp.), spikerushes (Eleocharis spp.),

milkweed, rough dogwood, and black willow (Salix nigra) (NRC 2003).

National Wetland Inventory maps accessed by the NRC staff on June 15, 2022, show a band of forested and emergent wetlands ranging bordering the Missouri River and extending landward by roughly 91.4 m (300 ft) to more than 183 m (600 ft) (FWS 2022a). The only place on the FCS site where the maps do not depict these riparian wetlands bordering the river is where the developed plant lands extend to the edge of the river. The maps also depict four small, isolated areas of palustrine wetlands, each under 0.4 ha (1 ac) in extent and roughly rectangular or trapezoidal in shape, within developed areas of the FCS site. These appear from the photographs to either not be wetlands or be too disturbed by development to be of ecological value.

The DeSoto National Wildlife Refuge comprises approximately 3,157 ha (7,800 ac) situated approximately 1.6 km (1 mi) east of the FCS site along the Missouri River (OPPD 2021). The refuge contains bottomland forests, tallgrass prairie, and wetlands and an oxbow lake that used to be a bend in the Missouri River. During the spring and fall the location and suitable habitats are host to a diversity of migratory birds as well as turtles and deer (FWS 2022b).

3.8.1.1 Federally Listed Species The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) jointly administer the Federal Endangered Species Act of 1973 (ESA). The FWS manages the protection of, and recovery effort for, listed terrestrial and freshwater species, and the NMFS manages the protection of and recovery effort for listed marine and anadromous species. This section discusses these species.

The implementing regulations for section 7(a)(2) of the ESA define action area as all areas affected directly or indirectly by the Federal action and not merely the immediate area involved in the action (50 CFR 402.02). The action area effectively bounds the analysis of ESA-protected species and habitats because only species that occur within the action area may be affected by the Federal action. Using the FWS Information for Planning and Consultation (IPaC) database, the NRC staff generated a species list dated August 2023 for an action area comprising the FCS site and immediately adjacent lands (FWS 2023a). The species list identified the following terrestrial species designated under the ESA as potentially occurring in the action area (table 2).

Table 2. Federally Listed Terrestrial Species at the FCS and in the Vicinity Species Description Federal Status Northern Long- Flying mammal, winters in hibernacula consisting of caves and Endangered eared Bat mines, disperses in spring to form summer maternity roosts in live (Myotis or dead trees with peeling (exfoliating) bark, forages for insects in septentrionalis) understory of forests (FWS 2022c). May roost or forage on or near the FCS site in areas of natural vegetation close to the Missouri River.

Tricolored Bat Flying mammal, winters in hibernacula consisting of caves and Proposed (Perimyotis mines, disperses in spring to form summer maternity roosts in live Endangered subflavus) or recently dead trees in forested areas and occasionally in human structures (FWS 2023b). May roost or forage on or near the FCS site in areas of natural vegetation close to the Missouri River.

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Piping Plover Shorebird, in northern Great Plains breeds and raises young on Threatened (Charadrius sparsely vegetated sandbars and shorelines, winters in the south melodus) on beaches and other coastal areas, populations have declined due to disturbance and degradation of breeding and wintering habitat (FWS 2016). Loss of sandbar nesting habitat caused by river channelization and flow changes from construction and operations of dams have resulted in population declines along the Missouri River (OPPD 2021). Aerial photography (figure 2.2) indicates that there is no sandbar habitat along the Missouri River shoreline where it abuts the FCS-developed areas, although photographs suggest that some sandbar habitat potentially favorable for the piping plover may occur more than 304.8 m (1,000 ft) downstream. Therefore, piping plover could occur in the action area.

Monarch Butterfly Insect, lay eggs on milkweed (Asclepias spp.) plants, populations Candidate (Danaus migrate to overwintering grounds south of the United States (FWS plexippus) 2022d). Milkweeds are herbaceous perennial plants of uplands and wetlands and might occur in the emergent wetlands on or near the FCS site in low areas close to the river.

The list also included one aquatic species, addressed below in section 3.8.2. The search did not include any critical habitats in the action area. The OPPD identified many of the same Federally listed species as the staffs search with a few exceptions noted below (OPPD 2021). The LTP did not address the tricolored bat, which the FWS is currently proposing as endangered, but which was not listed in any special status at the time. The LTP also did not discuss the monarch butterfly, which currently is still only a candidate species under consideration for Federal listing but not actually protected under the ESA. Additional information on the tricolored bat and monarch butterfly can be found in table 4 and section 4.3 of this EA. The northern long-eared bat, listed as threatened at the time of the LTP, was upgraded to endangered on March 31, 2023 (88 FR 4908-4910).

One additional species previously identified but not identified by the staffs 2023 search was the Least Tern (Sterna antillarum). The staffs search did not identify this species because it was delisted by the FWS in 2021 because of recovery (86 FR 2564-2581). As discussed below the NRC staff identified the Least Tern as a state-listed species and considered it below.

Additionally the, the LTP also identified the bald eagle (Haliaeetus leucocephalus), further discussed in section 3.8.1.3, as threatened, but the FWS had delisted it in 2007 (72 FR 37346).

State-Listed Species The LTP identifies the following terrestrial species that are listed in both the Nebraska Nongame and Endangered Species Conservation Act and the ESA as potentially occurring on or near the FCS site as of 2019 (OPPD 2021):

Table 3. State-Listed Terrestrial Species at the FCS and in the Vicinity Species Description State Status Northern Long-eared Bat See Above Threatened (Myotis septentrionalis)

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Species Description State Status Bald Eagle (Haliaeetus Large raptor (bird of prey), breeds and winters Threatened leucocephalus) in forested areas adjacent to large bodies of water (FWS 2022f). The shoreline where the operational area abuts the river is concrete and does not contain trees that bald eagles might use. Forested areas along Missouri River on and near the FCS site could provide suitable roosts and nesting habitat. The species is unlikely to use other areas on the FCS site.

Piping Plover See Above Threatened (Charadrius melodus)

Least Tern (Sterna Shorebird, nests and raises young on dry Endangered antillarum) riverine sandbars in wide, braided rivers and along shores of reservoirs and lakes (Nebraska Game & Parks 2022a. Aerial photography (figure 2.2) indicates that there is no sandbar habitat along the Missouri River shoreline where it abuts the FCS-developed areas. However, photographs suggest that some potentially favorable sandbar habitat for the least tern may occur downstream more than 304.8 m (1,000 ft) away. Therefore, the least tern could occur in the action area.

Massasauga Rattlesnake Reptile, small rattlesnake, live in wet areas Threatened (Sistrurus catenatus) including wet prairies, marshes, fens, sedge meadows, peatlands, and low areas along rivers and lakes (FWS 2022g). Areas of emergent and forested wetlands in low areas along the Missouri River may provide suitable habitat.

Western Prairie Fringed Plant, perennial orchid, found mostly in Threatened Orchid (Platanthera calcareous prairies and sedge meadows praeclara) without history of plowing, dependent on periodic fire, mowing, or grazing to maintain habitat (FWS 2022e). May occur in the emergent wetlands on or near the FCS site in low areas close to Missouri River.

Small White Ladys Slipper Plant, perennial, herbaceous, orchid, occurs in Threatened (Cypripedum candidum) wet meadows and moist prairies (Nebraska Game and Parks 2022b). May occur in emergent wetlands on or near the FCS site in low areas close to Missouri River.

American Ginseng (Panax Plant, perennial, herbaceous, occurs in Threatened quinquefolium) understory of dense forest with rich but not wet soils (Nebraska Game and Parks 2022c). May occur in riparian forest along the Missouri River on or close to the FCS site.

OPPDs list also includes three State-listed fish species, addressed below in section 3.8.2. The NRC considers possible impacts to State-listed species in its environmental impact statements, discussed below, but State-listed species are not addressed in consultations under Section 7 of the ESA. Any consultations that would have to be completed with state agencies would be performed by the OPPD.

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3.8.1.2 Migratory Birds The FWS administers the Migratory Bird Treaty Act of 1918 (MBTA), which prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. The MBTA protects a total of 1,093 migratory bird species (85 FR 21282). The NRC staffs above-mentioned IPaC search identified the following species of migratory birds designated as birds of priority concern by the FWS as in the area of the FCS:

• Bald Eagle (Haliaeetus leucocephalus)

• Black-billed Cuckoo (Coccyzus erythropthalmus)

• Bobolink (Dolichonyx oryzivorus)

• Chimney Swift (Chaetura pelagica)

• Henslows Sparrow (Ammodramus henslowii)

• Hudsonian Godwit (Limosa haemastica)

• Kentucky Warbler (Oporornis formosus)

• Lesser Yellowlegs (Tringa flavipes)

• Red-headed Woodpecker (Melanerpes erythrocephalus)

• Rusty Blackbird (Euphagus carolinus)

• Wood Thrush (Hylocichla mustelina) 3.8.1.3 Bald and Golden Eagle The bald eagle also is protected under the Bald and Golden Eagle Protection Act of 1940 (BGEPA). As discussed in table 3. The only areas of the FCS site likely to provide favorable habitat for the migratory bird species noted above are the Missouri River shoreline and adjoining low-lying areas of forest and wetland vegetation. The NRC staff expects that the OPPD would obtain any permits required under these two acts and that impacts to bald eagles would be evaluated as part of that permitting process.

3.8.1.4 Direct and Indirect Impacts Decommissioning GEIS Determination The GEIS concludes generically that the potential terrestrial impacts from decommissioning activities conducted within the operational area of a nuclear plant site are SMALL, although it indicates that a site-specific analysis is necessary to determine the significance of terrestrial ecology impacts from activities conducted outside of the operational area (NRC 2002). The GEIS acknowledges that lands disturbed by construction of a nuclear facility typically continue to be of low value as terrestrial habitat throughout operations and decommissioning unless the site goes into a decade-long period of low decommissioning activity (NRC 2002).

Site-Specific Activities The OPPD states in its PSDAR and LTP that it envisions that all dismantlement, demolition, and waste staging activities performed as part of decommissioning and license termination would take place within the former operational area of the FCS site (OPPD 2017a, the OPPD 2021).

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The OPPD indicates that land disturbance would not be conducted in environmentally sensitive lands, such as wetlands, on the site or where the site adjoins environmentally sensitive offsite lands (OPPD 2021). Direct impacts, in the form of physical disturbance, would therefore be limited to paved or grassy areas of low value as terrestrial habitat.

The OPPD acknowledges that terrestrial habitats adjoining the operational area could be subject to indirect impacts from decommissioning and license termination activities, caused by soil erosion, surface runoff, fugitive dust, and noise (OPPD 2017a, the OPPD 2021). The agricultural fields and grassy uplands adjoining the operational area on most sides would not be noticeably affected by these impacts, but the ecological quality of the forested and emergent wetlands and riparian forest land adjoining the operational area near the Missouri River could be adversely affected. The OPPD will obtain the storm water permits required by the Nebraska Department of Environmental Quality for areas of soil disturbance exceeding 04 ha (1 ac), which would require implementation of BMPs, such as a Stormwater Pollution Prevention Plan or drainage design, to control sediment and erosion that could affect adjoining terrestrial habitats (OPPD 2021). The OPPD also commits to control fugitive dust emissions through water spraying (OPPD 2021). The NRC staff concludes that the BMPs and water spraying proposed by OPPD would effectively minimize erosion, runoff, and fugitive dust and thereby prevent adverse impacts to terrestrial habitats outside of the operational area.

Birds and other wildlife using the wetlands and riparian lands adjoining the former operational area near the river could be affected by noise generated by decommissioning and license termination activity within the operational area. However, because the FCS is an established industrial site with a several-decade history of continuous industrial activity, it is reasonable to expect that wildlife using habitats near the site has generally acclimated to the noise and human activity typical of industrial sites, including the level of noise expected during decommissioning.

The OPPD commits to adhere to its Avian Protection Plan over the course of decommissioning and license termination activities. Although the plan focuses mainly on transmission line maintenance (not part of the decommissioning and license termination activities), the OPPD will apply the recommendations to its decommissioning activities. For example, the Avian Protection Plan calls for scheduling maintenance and demolition work to avoid, when possible, the period of most migratory bird nesting in Nebraska, which extends from April 1 through July 15 (OPPD 2016b). Certain decommissioning activities, especially demolition activities involving jackhammers or explosives, could generate brief noise bursts that might startle wildlife in nearby habitats. However, due to the short duration of those activities, the NRC staff expects that these noise occurrences would be too brief to noticeably affect nearby wildlife.

The NRC staff evaluated the possible impacts of decommissioning and license termination activities at the FCS on Federally listed species (see below) and determined that the activities may affect but are not likely to adversely affect (NLAA) each of the species. The results of this evaluation are summarized in table 4.

Table 4. Summary of Decommissioning and License Termination Activity Impacts on the Listed Species at the FCS and in the Vicinity (NLAA)

Species Federal Status Conclusion and Basis Northern Long- Endangered May Affect, NLAA. Species may forage or form maternity eared Bat roosts in forested wetlands and riparian forest outside of (Myotis the operational area along the shore of the Missouri septentrionalis) River, which would not be directly impacted by decommissioning activities. Further, the proposed action December 2023 3-21

Species Federal Status Conclusion and Basis would be confined to industrial lands lacking tree cover within the operational area and would not involve removal of any trees or forest cover. Therefore, the decommissioning activities may affect but are not likely to adversely affect this species because there are suitable habitats for the species in close proximity to the FCS that would not be impacted by decommissioning activities.

Tricolored Bat Proposed Endangered May Affect, NLAA. Species may forage or form maternity (Perimyotis roosts in forested wetlands and riparian forest outside of subflavus) the operational area along the shore of the Missouri River, which would not be directly impacted by decommissioning activities. Further, the proposed action would be confined to industrial lands lacking tree cover within the operational area and would not involve removal of any trees or forest cover. Therefore, the decommissioning activities may affect but are not likely to adversely affect this species because there are suitable habitats for the species in close proximity to the FCS that would not be impacted by decommissioning activities.

Piping Plover Threatened May Affect, NLAA. Sandbars along the Missouri River (Charadrius could provide suitable nesting habitat for piping plovers.

melodus) The shoreline where the operational area abuts the river is concrete and does not contain sandbars that piping plovers might use. Natural shorelines, where the relevant sandbars could occur, are located farther from the operational area. Decommissioning activities would be confined to existing operational area and would not physically disturb the shoreline of the natural shoreline Missouri River. Piping plovers nesting elsewhere along the Missouri River in natural shoreline habitats (i.e.,

outside the operational area) might experience noise caused by activities in the operational area, but the noise would be typical of industrial activity that has occurred for decades at the FCS site. Any increased noise caused by demolition work would be temporary and staff anticipates that the short duration would not result in nest abandonment. The OPPD states that cooling water withdrawals from the Missouri River would significantly decrease (OPPD 2021), which might slightly increase the availability of shoreline sandbars, possibly increasing suitable nesting habitat. Therefore, the decommissioning activities may affect but are not likely to adversely affect this species.

Monarch Candidate May Affect, NLAA. Physical disturbance is mostly likely to Butterfly take place within the existing operational area. Milkweed, (Danaus the plants required by breeding monarch butterflies, are plexippus) unlikely to occur on the paved lands and mowed grasslands within the existing operational area. Milkweed might occur in the naturally vegetated lands adjoining the December 2023 3-22

Species Federal Status Conclusion and Basis operational area, but the action would not directly disturb these lands. With regard to indirect disturbance, BMPs proposed by the OPPD such as wetting the soil and developing a stormwater pollution prevention plan would protect any milkweed from damage by sedimentation, runoff, or fugitive dust. Therefore, the decommissioning activities may affect but are not likely to adversely affect this species.

The NRC staff has also determined that the decommissioning and license termination activities would have at most minimal impacts on each State-listed species potentially occurring in the area, as described in Error! Not a valid bookmark self-reference..

Table 5. Summary of Decommissioning and License Termination Activity Impacts on the State-Listed Species at the FCS and in the Vicinity (Minimal Impacts)

Species State Status Conclusion and Basis Northern Long- Threatened Minimal Effects. See analysis above in table 4 for Federal species.

eared Bat (Myotis septentrionalis)

Bald Eagle Threatened Minimal Effects. Eagles might roost or nest in trees along the (Haliaeetus Missouri River shoreline which are located outside the operational leucocephalus) area. Impacts related to decommissioning activities would be limited to the existing operational area and would not extend into areas where eagles might nest. Thus, no additional roosting or nesting trees would we impacted. Therefore, a minimal, if any, impact could occur.

Least Tern Endangered Minimal Effects. Sandbars along the Missouri River could provide (Sterna suitable nesting habitat for least terns. The shoreline where the antillarum) operational area abuts the river is concrete and does not contain sandbars that least terns might use. Natural shorelines, where the relevant sandbars could occur, are located farther from the operational area. Decommissioning activities would be confined to existing operational area and would not physically disturb the shoreline of the Missouri River. Least terns nesting elsewhere along the Missouri River in natural shoreline habitats (i.e., outside the operational area) might experience noise caused by activities in the operational area, but the noise would be typical of industrial activity that has occurred for decades at the FCS site. Any increased noise caused by demolition work would be temporary and, staff anticipates, that the short duration would not result in nest abandonment. The OPPD states that cooling water withdrawals from the Missouri River would significantly decrease (OPPD 2021), which might slightly increase the availability of shoreline sandbars, possibly increasing suitable nesting habitat. Therefore, a minimal, if any, impact could occur.

Massasauga Threatened Minimal Effects. Physical disturbance is most likely to take place within Rattlesnake the existing operational area. This reptile is unlikely to occur in the (Sistrurus paved lands and mowed grasslands within the existing operational area catenatus) because those are not typical suitable habitats. It might inhabit the naturally vegetated lands adjoining the operational area, but the action would not directly disturb these lands. With regard to indirect disturbance, BMPs proposed by the OPPD such as wetting the soil and developing a December 2023 3-23

Species State Status Conclusion and Basis stormwater pollution prevention plan would protect vegetated areas that would be suitable habitats from sedimentation, runoff, and fugitive dust.

Therefore, a minimal, if any, impact could occur.

Western Prairie Threatened Minimal Effects. Physical disturbance is most likely to take place within Fringed Orchid the existing operational area. This perennial prairie plant is unlikely to (Platanthera occur in the paved lands and mowed grasslands within the existing praeclara) operational area. The plant might occur in unforested areas within the naturally vegetated lands adjoining the operational area, but the action would not directly disturb these lands. With regard to indirect disturbance, BMPs proposed by the OPPD such as wetting the soil and developing stormwater pollution prevention plan would protect vegetated areas potentially containing this plant from damage by sedimentation, runoff, or fugitive dust. Plants are not affected by noise. Therefore, a minimal, if any, impact could occur.

Small White Threatened Minimal Effects. Physical disturbance is most likely to take place Ladys Slipper within the existing operational area. This perennial wetland plant is (Cypripedum unlikely to occur in the paved lands and mowed grasslands within the candidum) existing operational area. The plant might occur in wetlands adjoining the operational area, but the action would not directly disturb these lands.

With regard to indirect disturbance, BMPs proposed by the OPPD such as wetting the soil and developing stormwater pollution prevention plan would protect wetlands potentially containing this plant from damage by sedimentation, runoff, or fugitive dust. Plants are not affected by noise.

Therefore, minimal, if any, impact could occur.

American Threatened Minimal Effects. Physical disturbance is most likely to take place Ginseng within the existing operational area. This plant is unlikely to occur in the (Panax paved lands and mowed grasslands within the existing operational area.

quinquefolium) The plant might occur in the forested areas adjoining the operational area, but the action would not directly disturb these lands. With regard to indirect disturbance, BMPs proposed by the OPPD such as wetting the soil and developing stormwater pollution prevention plan would protect lands containing this plant from damage by sedimentation, runoff, or fugitive dust. Plants are not affected by noise. Therefore, minimal, if any, impact could occur.

The NRC staff concludes that the overall direct and indirect impacts to terrestrial ecology would be SMALL. In general, this conclusion is based on the generic determination in the GEIS regarding the SMALL significance of decommissioning activities on the licensees site. For the FCS, the OPPD also commits to implementing BMPs to protect areas outside the operational area from sedimentation, runoff, and fugitive dust. Furthermore, species in the vicinity of the decommissioning activities would encounter decommissioning noise levels similar to the noise associated with the site during operations to which species would be acclimated. Specifically, for ecological habitatss plan to limit land disturbance from decommissioning and license termination activities to the existing operational area would be protective of both Federally and State-listed species. The NRC staff has determined that the actions may affect, but are not likely to adversely affect, each Federally listed terrestrial species potentially occurring in the affected area as well as any birds covered by the MBTA and BGEPA. The NRC staff has also determined that the actions would have only minimal effects on each State-listed terrestrial species potentially occurring in the affected area.

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3.8.2 Aquatic Resources 3.8.2.1 Aquatic Habitats The principal aquatic habitat in the vicinity of the FCS is associated with the adjoining reach of the Missouri River. The river channel is approximately 183 m (600 ft) wide and 4.5 m (15 ft) deep where it passes the FCS site (NRC 2003). Habitat for aquatic species has been degraded due to channelization of this reach (NRC 2003). The SEIS summarizes the results of multiple fish surveys for the reach of the Missouri River near the FCS. The most abundant fish species collected from the reach in a 1978 study included common carp (Cyprinus carpio), freshwater drum (Aplodinotus grunniens), gizzard shad (Dorosoma cepedianum), and river carpsucker (Carpiodes carpio) (NRC 2003). Electroshocking data from 1982 indicated that the most abundant fish species in the Missouri River near the FCS were the gizzard shad, goldeye (Hiodon alosoides), common carp, western silvery minnow (Hybognathus argyritis), silver chub (Macrhybopsis storeriana), emerald shiner (Notropis atherinoides), river shiner (Notropis blennius), red shiner (Cyprinella lutrensis), river carpsucker, and freshwater drum (NRC 2003).

Commercial and recreational harvest of several fish species occurs in the reach (NRC 2003).

Habitat in the Missouri River near the FCS is not conducive to colonization by freshwater mussels because of its channelization, swift current, high turbidity, and unstable substrates (NRC 2003).

3.8.2.2 Federally Listed Species The NRC staff generated a species list dated January 19, 2023, for an action area comprising the FCS site and immediately adjacent lands using the FWS IPaC database (FWS 2023a). As previously discussed, the action area effectively bounds the analysis of ESA-protected species and habitats because only species that occur within the action area may be affected by the Federal action. The species list identified only one aquatic species designated under the ESA as potentially occurring in the action area: the pallid sturgeon (Scaphirhynchus albus), listed as endangered (

table 6). The list did not include any critical habitats. The LTP prepared by the OPPD in 2021 and the PSDAR initially prepared by the OPPD in 2017 and the updated PSDAR, submitted in 2019, also identify the pallid sturgeon as the only Federally listed aquatic species potentially affected by decommissioning the FCS.

Table 6. Federally Listed Aquatic Species at the FCS and in the Vicinity Species Description Federal Status Pallid Sturgeon Bottom-oriented, large-river fish obligate to large rivers found in Endangered (Scaphirhynchus the Missouri and Mississippi Rivers and some larger tributaries albus) (FWS 2022h). Dam construction has adversely altered habitat for this long-lived fish, and many reproductively mature fish are thought to have been born before the dams were constructed (Nebraska Game and Parks 2022d). Only potentially suitable habitat on or near the FCS site is the Missouri River.

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3.8.2.3 State-Listed Species The LTP identifies three aquatic species that are listed under both the Nebraska Nongame and Endangered Species Conservation Act and ESA as potentially occurring on or near the FCS site as of 2019 (table 7) (OPPD 2021):

Table 7. State-Listed Aquatic Species at the FCS and in the Vicinity Species State Status Description Pallid Sturgeon Endangered See (Scaphirhynchus table 6 albus)

Lake Sturgeon Threatened Similar to the Pallid Sturgeon but more common than pallid (Acipenser sturgeon in Mississippi and St. Lawrence River systems. It is fulvescens) uncommon in Missouri River running through Nebraska (Nebraska Game and Parks 2022d). Only potentially suitable habitat on or near the FCS site is the Missouri River.

Sturgeon Chub Threatened Small, minnow-like fish favoring fast, free flowing river habitat (Macrhybopsis with high turbidity (Nebraska Game and Parks 2022e). Only gelida) potentially suitable habitat on or near the FCS site is the Missouri River.

The Magnuson-Stevens Fishery Conservation and Management Act, as amended, (MSA)

(16 U.S.C §1801 et seq.) requires Federal agencies to consult with the NMFS on actions that may adversely affect essential fish habitat (EFH). The NMFS has not designated any EFH under the MSA within affected water bodies in the vicinity of the proposed site. (NOAA 2022).

Because no habitats are designated, no EFH would be affected by the proposed action.

Therefore, this section does not discuss species with EFH.

3.8.2.4 Direct and Indirect Impacts Decommissioning GEIS Determination The GEIS concludes generically that the potential impacts to aquatic ecology from decommissioning activities conducted within the operational area of a nuclear plant site are SMALL, although it indicates that a site-specific analysis is necessary to determine the significance of aquatic ecology impacts from activities conducted outside of the operational area (NRC 2002). The SMALL conclusion in the GEIS assumes that applicable BMPs are implemented and that necessary permits are obtained.

The GEIS determined that site-specific analysis is necessary to evaluate the significance of impacts to threatened or endangered species (NRC 2002).

Site-Specific Activities The OPPD states in its LTP that it would continue to maintain its existing NPDES permit and would perform decommissioning work in compliance with the permit and implement BMPs as appropriate (OPPD 2021). The OPPD Storm Water Pollution Prevention Plan contains BMPs that address sediment and erosion discharges to watercourses and wetlands, and the OPPD states in its LTP that all BMPs would be in place prior to initiating decommissioning activities (OPPD 2021). Because the decommissioning activities would be contained within the previously disturbed area, the direct and indirect impacts outside the operational area would be minimal.

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The only place on or near the FCS where any of the three species listed in table 7 could occur is the Missouri River. During operations, the FCS drew water from the Missouri River to cool reactor systems and discharged cooling blowdown water into the Missouri River. Because the FCS is no longer operating, it no longer needs to withdraw as much water or discharge the cooling water. Therefore, decommissioning would require a much smaller amount of water from the river to dilute liquid waste generated during decommissioning (OPPD 2021).

During operation, the FCS used a maximum of 23 cubic meters per second (m3/s) (30 cubic yards per second (yd3/s)) of water from the Missouri River, accounting for 2-4 percent of the total river flow, depending on the season (NRC 2003). Decommissioning activities would not require water from the Missouri River to use as coolant; therefore, the volume of intake would significantly decrease. This would, thus, reduce the potential for impingement and entrainment of aquatic organisms. Further, the FCS will no longer discharge warmer-than-ambient temperature water (thermal discharges) to the aquatic habitat (OPPD 2021), thus reducing the impact from temperature increases to the water system and aquatic life. Reducing these impacts to aquatic biota and habitat might slightly benefit any fish in the river. Adherence to the NPDES permit (discussed in section 3.6.1.1) and implementation of the BMPs, such as the Stormwater Pollution Prevention Plan and drainage design, would protect any aquatic species present in the river from runoff and sedimentation originating from the FCS site.

The NRC staff evaluated the possible impacts of decommissioning and license termination activities at the FCS on the pallid sturgeon (table 8) and determined that the activities may affect but are NLAA the species. For the same reasons, the potential impacts on the two other state-listed fish species would be minimal (table 9).

Table 8. Summary of Decommissioning and License Termination Activity Impacts on the Listed Species at the FCS and in the Vicinity (NLAA)

Species Federal Status Conclusions and Basis Pallid Sturgeon Endangered May Affect, NLAA. Reduced intake from and discharge to the (Scaphirhynchus river, eventually terminating once decommissioning is complete.

albus) Continued maintenance of NPDES permit and implementation of BMPs. Therefore, there would be minimal impacts from decommissioning activities that would eventually cease.

Table 9. Summary of Decommissioning and License Termination Activity Impacts on the State-Listed Species at the FCS and in the Vicinity (Minimal Impacts)

Species State Status Conclusions and Basis Pallid Sturgeon Endangered Minimal. Reduced intake from and discharge to the river, eventually (Scaphirhynchus terminating once decommissioning is complete. Continued albus) maintenance of NPDES permit and implementation of BMPs.

Therefore, therefore would be minimal impacts from decommissioning activities that would eventually cease.

Lake Sturgeon Threatened Minimal. Reduced intake from and discharge to the river, eventually (Acipenser terminating once decommissioning is complete. Continued fulvescens) maintenance of NPDES permit and implementation of BMPs.

Therefore, there would be minimal impacts from decommissioning activities that would eventually cease.

Sturgeon Chub Threatened Minimal. Reduced intake from and discharge to the river, eventually (Macrhybopsis terminating once decommissioning is complete. Continued gelida) maintenance of NPDES permit and implementation of BMPs.

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Therefore, there would be minimal impact from decommissioning activities that would eventually cease.

The NRC staff concludes that the direct and indirect aquatic ecology impacts would be SMALL.

This conclusion is based, in part, on the generic determination in the GEIS regarding the SMALL significance of decommissioning activities on the operational area. The OPPD plan to limit land disturbance from decommissioning and license termination activities to the existing operational area; and it plans to maintain the existing NPDES permit and implement BMPs throughout decommissioning. These actions would protect the Missouri River from sedimentation, runoff, and fugitive dust. It also reflects the fact that the NRC staff has determined that the actions may affect, but are not likely to adversely affect, the only Federally listed aquatic species occurring in the area, the pallid sturgeon, and that the NRC staff has determined that the actions would have only minimal effects on each State-listed aquatic species potentially occurring in the affected area.

3.9 Socioeconomics 3.9.1 Socioeconomic Characteristics of the Site Vicinity This section describes current socioeconomic factors that have the potential to be directly or indirectly affected by the proposed LTP at the FCS. The FCS and the communities that support it can be described as a dynamic socioeconomic system. The communities supply the people, goods, and services required to conduct decommissioning activities. Decommissioning activities, in turn, supply wages and benefits for people and revenue for the community from the sale of goods and services to the FCS. The measure of a communitys ability to support the proposed LTP depends on its ability to respond to changing environmental, social, economic, and demographic conditions.

Potential socioeconomic impacts during decommissioning include increased demand for short-term housing, public services, and increased traffic due to temporary fluctuations in the size of the workforce required to implement the LTP at the FCS. Any changes in employment and tax payments caused by decommissioning and license termination activities could have a direct and indirect impact on community services and housing demand, as well as traffic volumes in the communities around the FCS site.

In general, there are two ways in which decommissioning activities may have a social and economic impact on a community and its surrounding area: (1) through expenditures in the community by the facility workforce and direct purchase of goods and services necessary for facility operations and (2) the effects of decommissioning on local government tax revenues and services (NRC 2002).

The region of influence is defined by the areas where the majority of the FCS workers and their families reside, spend their income, and use their benefits, thus affecting the economic conditions of the regions. The majority of the FCS workers reside in Washington, Douglas, and Sarpy Counties. Therefore, the focus of this analysis is on these three counties. According to the 2020 U.S. Census Bureau, an estimated combined 795,995 people lived in Washington (20,865), Douglas (584,526), and Sarpy (190,604) Counties (USCB 2022a). When the FCS shutdown in October 2016, there were approximately 650 employees (OPPD 2022). There are approximately 335 workers (OPPD employees and contractors) currently at the FCS site, and the OPPD estimates that the workforce will continue to fluctuate through the completion of December 2023 3-28

decommissioning, but an overall decline is expected, with approximately 40 workers remaining at the completion of decommissioning and after decommissioning is complete.

3.9.2 Socioeconomic Direct and Indirect Impacts Decommissioning GEIS Determination According to Appendix J of the Decommissioning GEIS, population changes greater than 3 percent to a local population could have detectable socioeconomic effects in local communities. Changes in tax revenues of less than 10 percent are considered not detectable; that is, they result in little or no change in local property tax rates and the provision of public services. The impacts of decommissioning on public services are generally much smaller than the impacts of plant closure. Impacts of closure are closely related to the tax-related impacts on the community and are affected by the same characteristics of the plant (size and age, tax treatment, and dependence of the local community on plant-related revenues). The impacts of plant closure are those that are observed by the community, rather than the impacts from decommissioning activities because they occur at about the same time. The impacts occur either through changing employment levels and local demands for housing and infrastructure, or through decline of the local tax base and the ability of local government entities to provide public services. The GEIS concluded that the socioeconomic impacts from decommissioning are SMALL.

Site-Specific Activities Reduction in the FCS workforce from 335 workers to 40 represents a change of less than 1 percent in the combined three-county region of influence population of 795,995 and a change of less than a 2 percent in the individual county populations. Therefore, the reduction in workers is not expected to have detectable socioeconomic effects to local communities. The OPPD is exempt from paying State-occupational, personal-property, and real estate taxes (NRC 2003).

However, has made payments in lieu of taxes to 13 counties totaling approximately

$34-$39 million/year from 2017 through 2021 (OPPD 2022). Although these payments went to a broader set of communities than those in the region of influence, the NRC staff is limiting the region of influence to those three counties because they are the most affected and most of this money went to those counties. Payments in lieu of taxes or other payments to local jurisdictions are not anticipated to change noticeably during the decommissioning phase. In accordance with Nebraskas State Constitution, Article VIII, Section 11, public corporations and political subdivisions providing electricity, which includes the OPPD, are required to annually make the same payments in lieu of taxes as it made in 1957 and allocate them in proportion to how they were made in 1957. Furthermore, if the public corporation sells electricity at retail to a city or village, it also will pay to the treasurer of the county where the city or village is located a sum of five percent of the annual gross revenue the public corporation derived from retail sales of electricity.

In accordance with Nebraskas Constitution, the OPPD will continue payments in lieu of taxes to the municipalities and 12 counties in which the OPPD sold power in 1957 for as long as the NRC license remains in effect. Furthermore, the OPPD is responsible for the production and distribution of electricity within its 13-county service area. Even with the shutdown of the FCS, the OPPD will be responsible for producing and distributing electricity to the area surrounding the FCS site (OPPD 2022). Therefore, the OPPD will continue to make in lieu of tax payments each year from electricity sales and 1957 payments (OPPD 2022).

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Based on the discussions presented above, the NRC staff expect no impact associated with socioeconomics beyond those discussed in the GEIS.

3.10 Public and Occupational Health The intent of decommissioning is to reduce radiological contamination at the site to meet the NRC requirements for unrestricted use. Potential human health hazards associated with decommissioning the FCS range from potential exposure to very low levels of radioactivity in soils to elevated levels of radioactivity within the remaining facility and support structures and systems (e.g., remaining lines and sumps).

All facilities that the NRC licenses must adhere to the radiation protection standards in 10 CFR Part 20 to protect workers and the public against potential health risks from exposure to radioactive material used, generated, and released from the licensed facility. In the GEIS, the NRC determined that the radiological impacts to public and occupational health would remain within regulatory limits.

3.10.1 Existing Radiological Conditions The FCS was placed in SAFSTOR condition (a period of safe storage of the stabilized and defueled facility) on October 24, 2016. It remained in SAFSTOR condition until December 2019, when the OPPD changed the decommissioning method to DECON. The three years in SAFSTOR allowed for decay of most short-lived radionuclides and reduced radiation levels at the FCS. The OPPD has a radiation protection program (RPP) in accordance with 10 CFR 20 requirements that it will continue to implement during decommissioning.

As part of its current license, the FCS site has an RGPP based on with the Nuclear Energy Institute Technical Report 07-07, Industry Groundwater Protection Initiative - Final Guidance Document (NEI 2007). This program along with the ODCM and REMP will continue during decommissioning (OPPD 2019). The RGPP and the REMP are used to assess radiological impacts and monitor adherence to the ODCM (OPPD 2021). The REMP provides annual reports of the radiological environment in and around the FCS site and demonstrates compliance with the NRCs regulatory limits. Adherence to both the RGPP and REMP helps to minimize radiological impacts to groundwater.

3.10.2 Public and Occupational Dose Health and Safety Direct and Indirect Impacts Decommissioning GEIS Determination The GEIS estimated occupational cumulative doses for PWRs using the DECON option to be 560 to 1,000 person-rem (5.6 to 10 person-Sv). The GEIS made the generic determination that the radiological impacts of decommissioning, including license termination activities, are SMALL because the expected doses will remain within regulatory limits (NRC 2002)..

In the GEIS, the NRC determined that the levels of radionuclide emissions were lower for facilities undergoing decommissioning compared to operating facilities. Collective doses to public members were lower than 1 person-rem (0.01 person-Sv) per year within 80 km (50 mi) of the facilities. The maximally exposed individual was estimated to receive a dose of less than 1 mrem/yr (0.01 mSv/yr), which is well within the regulatory limits of 10 CFR Part 20 (NRC 2002).

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Site-Specific Activities Until the termination of the license, power reactor licensees are required to keep releases of radioactive materials to unrestricted areas at ALARA levels and are required to meet 10 CFR 50.36a requirements for effluent releases after ceasing operations (NRC 2002). Licensees also must comply with the EPAs standards in 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations (NRC 2002). During the remainder of the decommissioning process, the OPPD will continue to use the various protection programs and ALARA goals to ensure public and occupational protection in accordance with 10 CFR Part 20 and 10 CFR Part 50, Appendix I (OPPD 2019).

The OPPD estimates total radioactive exposure to be 230 person-rem (2.3 person-Sv) for decommissioning and spent fuel management (OPPD 2021) which is less than the GEISs estimate.

The OPPD is proposing DCGLs as acceptable levels of residual radioactivity that can be left at the FCS to comply with the unrestricted use criteria specified in 10 CFR 20.1402. As part of the NRC decision on whether to approve the LTP, the NRC will evaluate the adequacy of the DCGLs to provide protection for members of the public after termination of the license. In addition, because the proposed DCGLs exceed soil concentration values established in the Memorandum of Understanding (MOU) the NRC has with the EPA, the NRC is consulting with the EPA (NRC 2023a). Should the NRC staff approve the LTP after the conclusion of the consultation process, following site remediation activities, the licensee will submit a final site survey. The NRC staff will review the information contained in this survey report and will compare the remaining levels of residual radioactivity to the MOU trigger levels. If the final site survey measurements show that the remaining radionuclide concentrations are below the values set forth in the MOU as well as the final approved DCGL values, then the NRC will proceed to terminate the FCS license (except for the ISFSI), and the site will be released for unrestricted use. The NRC will inform the EPA of such findings. If the final site survey measurements show that the remaining radionuclide concentrations are above the values set forth in the MOU, then the NRC will engage in Level 2 consultation with the EPA to identify and resolve any remaining issues. Additionally, Nebraska regulations require FCS to notify the Nebraska Department of Environment and Energy for excavations encountering contamination, or in areas of known contamination (State of Nebraska 2023).

Because of OPPDs implementation of the RGPP, REMP, and ALARA goals to ensure public protection as discussed above, the NRC staff expects no impact associated with public and occupational dose beyond those discussed in the GEIS.

3.11 Transportation and Traffic 3.11.1 Transportation Affected Environment Radioactive waste will be transported from the FCS site by truck or rail. To make sure areas at the site are not cross-contaminated during decommissioning, the OPPD has established dedicated waste haul routes (i.e., single-usage routes) for radioactive and nonradioactive waste which would mitigate the potential for contaminated material to come in contact with uncontaminated material. Figure 7 illustrates the dedicated haul roads and rail lines. Removal of construction materials, debris, and equipment from the FCS site will likely occur by truck and will include varying periods of heavier and lighter activity during active decommissioning. The OPPD estimates an average of eight truck trips per day for waste removal over the course of active December 2023 3-31

decommissioning. When trucks from the FCS are added to the 2018 Nebraska Department of Transportation average of 585 heavy vehicles per day from the FCS vicinity, total truck traffic is lower than the 640 heavy vehicles per day recorded while the FCS was in service (OPPD 2021).

Because of the availability of a rail line, a substantial portion of the radioactive waste shipments will likely use rail as the transport method to the disposal facilities in Clive, Utah. Rail shipments from the FCS would be a small fraction of the normal rail transport volume and provide no additional traffic impact on those railways (OPPD 2022). The OPPD will comply with all applicable NRC and U.S. Department of Transportation regulations, including the Federal Railroad Administration requirements and State of Nebraska regulations, and will use approved packaging and shipping containers for waste shipments (OPPD 2019).

Figure 7. Waste Enclosures and Haul Paths (Source: OPPD 2021) 3.11.2 Transportation Direct and Indirect Impacts Decommissioning GEIS Determination The GEIS addressed impacts to transporting equipment and materials offsite. Materials discussed in the GEIS include low-level radioactive waste (LLW), hazardous and nonhazardous wastes, and mixed waste. Radiological impacts include exposures to the public and workers along the transportation route. The GEIS states that transportation impacts include increases in traffic density, wear and tear on roadways and railways, and transportation accidents. While this analysis was primarily based on material leaving the site, those impacts would also apply to truck traffic bringing material (such as clean backfill soils) to the site (NRC 2002). The December 2023 3-32

Decommissioning GEIS estimates that shipment of LLW by rail rather than by truck would reduce radiological impacts significantly (NRC 2002).

Regarding transportation accidents, the GEIS states that, historically, the accident rate for activities at nuclear facilities has been lower than the national average for similar activities, attributed to the nuclear industry emphasis on training and procedures (NRC 2002). The GEIS assumed most decommissioning waste would be transported by truck. The GEIS concluded that the radiological impacts from transportation, based on compliance with applicable regulations, would not be detectable or destabilizing.

Impacts are considered destabilizing if increased traffic causes a decrease in the level of service or measurable deterioration of affected roads can be tied directly to the activities at the site (NRC 2002). The GEIS concluded that the impact to transportation from decommissioning is SMALL.

Site-Specific Activities The NRC expects that the FCS will comply with all regulations and requirements for transport of waste and materials. Although the number of shipments and the volume of waste shipped are greater during decommissioning than during the operation of the facility, the majority of the waste will be transported by rail. The work force at the FCS has decreased significantly from the time the plant ceased operation to a work force of approximately 300 people. The work force will temporarily increase during decommissioning due to specific decommissioning and demolition activities. However, the work force during decommissioning will be smaller than the work force needed during plant construction and routine refueling/maintenance operations (OPPD 2022).

Therefore, the overall reduction in the FCS site employees as compared to operations should offset any small increase in decommissioning waste truck traffic (OPPD 2022). While there would be a minor temporary increase in traffic due to decommissioning activities, including commuter traffic, the traffic impacts on the larger capacity roads surrounding the FCS would not be noticeable or destabilizing with minimal road wear and tear. Thus, the NRC staff expects no impacts associated with transportation beyond those discussed in the GEIS.

3.12 Environmental Justice The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health and environmental effects on minority and low-income populations that could result from activities associated with the proposed action. Such effects may include human health, biological, cultural, economic, or social impacts. Minority and low-income populations are subsets of the general public residing in the vicinity of the FCS site, and all are exposed to the same health and environmental effects generated from activities at the FCS.

3.12.1 Minority Populations in the Vicinity of the FCS Site According to the 2020 Census, about 24 percent of the State of Nebraskas population identified themselves as minorities, with persons of Hispanic, Latino, or Spanish origin of any race comprising the largest minority population (USCB 2022a). The percentage of the population residing in the vicinity of the FCS site that identified themselves as minorities is lower than the percentage of the overall population of the State of Nebraska identifying as such.

According to the 2010 Census, approximately 5 percent (approximately 6,986 individuals) of the total population residing within a 6.4 km (4-mi) radius of the FCS identified themselves as minority (MCDC 2022a). The largest minority population was Hispanic, Latino, or Spanish origin December 2023 3-33

of any race. According to the U.S. Census Bureaus 2016-2020 American Community Survey 5-Year Estimates, the percentage of the population residing within a 6.4 km (4-mi) radius of the FCS identified themselves as minority had decreased to 3 percent (approximately 7,337 individuals) of the total population (MCDC 2022b).

3.12.2 Low-income Populations in the Vicinity of the FCS Site According to the U.S. Census Bureaus 2016-2020 American Community Survey 5-Year Estimates, the median household income for Nebraska was $63,015, while 6.6 percent of families and 10.4 percent of the state population were found to be living below the Federal poverty threshold (MCDC 2022b). The 2020 Federal poverty threshold was $26,496 for a family of four (USCB 2022c). According to the U.S. Census Bureaus 2016-2020 American Community Survey 5-Year Estimates, approximately 11 percent of individuals and 11 percent of families residing within a 6.2-km (4-mi) radius of the FCS were identified as living below the Federal poverty threshold (USCB 2022b).

3.12.3 Direct and Indirect Impacts Decommissioning GEIS Determination As discussed in the GEIS, minority and low-income populations (see sections 3.12.1 and 3.12.2) are subsets of the general public residing in the vicinity of a power plant. Potential impacts to minority and low-income populations would consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts) and radiological effects. Radiation doses during decommissioning are expected to remain well below regulatory limits. For environmental justice, the GEIS concluded that a site-specific analysis was necessary.

Site-Specific Activities As discussed in section 3.9.1, the maximum workforce for decommissioning is 335 workers, but an overall decline is expected with approximately 40 workers remaining at the completion of decommissioning. An average of eight trucks per day is estimated over the course of active decommissioning. Given the overall decrease in worker vehicles (i.e., reduced commuter traffic) and small daily increase in trucks with decommissioning waste (relative to no trucks related to the FCS), impacts to minority and low-income populations residing along site access roads from minor temporary increased traffic is not anticipated.

According to the 2016-2020 American Community Survey 5-Year Estimates, there was a combined total of approximately 18,603 vacant housing units in Washington, Douglas, and Sarpy Counties (USCB 2022d). Therefore, any increase in demand for rental housing during major decommissioning activities could be accommodated with a minimal impact on housing accessibility.

Noise primarily results from demolition activities, worker vehicles, and transportation of waste via trucks and rail. Given the overall decrease in the number of workers and, therefore, the number of worker vehicles, the NRC staff anticipates any increase in noise levels caused by transportation of waste and demolition activities would be minimal. This is because shipments will occur along existing roads and rail corridors, a substantial increase in truck and rail transport activity will not occur, and any additional noise will be intermittent. Further, noise impacts from demolition would be limited to onsite activities within the site boundary. As discussed in section December 2023 3-34

3.4.2, the potential noise impacts from decommissioning including license termination activities are SMALL. Because the nearest residence and community is 0.8 km (0.5 mi) and 4.8 km (3.0 mi), respectively, away and noise dissipates with increasing distance, it is likely that noise at the nearest residence and community from FCS decommissioning activities would be minimal (OPPD 2021). Apart from demolition, license termination activities (e.g., site radiological surveys and scans) would generate a minimal amount of noise and would not noticeably increase noise beyond the level associated with an industrial site. Therefore, any impacts for increases in noise from decommissioning activities would be minimal and would not have a disproportionately high and adverse effect on minority and low-income populations.

Increases in air emissions will be primarily from the demolition of buildings, dismantling of reactor components, and movement of material onsite. As discussed in section 3.3.4, air emissions from these activities will be temporary and minor and would not be above the other air emissions of other industrial facilities. Air emissions such as vehicle and equipment exhaust and fugitive dust will be monitored during decommissioning activities and continue to be monitored in the current air monitoring program to ensure that minority and low-income populations were not disproportionately affected.

Based on this information and the analysis of human health and environmental impacts presented in this EA, the decommissioning and LTP would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations residing in the vicinity of the FCS.

3.13 Waste Management Decommissioning generates large volumes of waste, both radioactive and nonradioactive (e.g., hazardous, municipal, and demolition), primarily from the dismantling of buildings and equipment. Decommissioning activities at the FCS site are subject to non-NRC Federal and State of Nebraska regulations, permits, licenses, notifications, and approvals, including those for hazardous waste generation and disposition, handling and removal of asbestos, handling and removal of lead paint, and removal of underground storage tanks. Chapter 2 (Site Characterization) of the LTP provides a description of historical spills and other events at the FCS site that may have contaminated site structures or soils with radiological or chemical constituents (OPPD 2019). Chapter 2 of the LTP also describes numerous studies, analyses, and other efforts to characterize the site in detail to determine the extent of radiological and nonradiological contamination and estimate the quantities of wastes for disposal onsite (e.g., clean concrete) or offsite (e.g., municipal waste or LLW) (OPPD 2019).

3.13.1 Radioactive Waste Large volumes of LLW will result from decommissioning activities. These wastes will include concrete, metal, and asphalt, contaminated water, used disposable protective clothing, expended abrasive and absorbent materials, expended resins and filters, materials for contamination control, and contaminated tools and equipment (OPPD 2021). The largest volume of LLW will result from activated and contaminated structures, systems, and components.

A radiological assessment will be performed after demolition of the containment building and radwaste processing building to verify that the area meets unrestricted use release criteria.

Radioactive waste from the containment building will be loaded directly into trucks or containers for removal through a temporary enclosure outside of the equipment hatch and then transported December 2023 3-35

to an enclosure at the rail spur (OPPD 2021). The auxiliary building will be demolished, and the remaining basement and embedded piping will undergo a final status survey to verify that it complies with unrestricted release criteria requirements in 10 CFR 20.1402. Sanitary sewage buried piping and lift stations will be removed and then disposed of as radioactive waste (OPPD 2021). A radiological assessment will be performed after excavation of the sewage lagoons and removal of contaminated soils to ensure all contaminated material has been removed prior to backfilling.

The reactor vessel internal components will be segmented prior to packaging. This activity will be performed under water to lower dose rates and reduce contamination. The segmentation will produce Class A, Class B/C, and Greater than Class C (GTCC) waste.

The NRC has adopted a waste classification system for LLW based on its potential hazards, and has specified disposal and waste form requirements for each of the general classes of waste: Classes A, B, and C. The classifications are based on the key radionuclides present in the waste and their half-lives. In general, requirements for waste form, stability, and disposal methods become more stringent when going from Class A to Class C waste. Waste classified as GTCC exceeds the concentration limits in 10 CFR 61.55 and is generally unsuitable for near-surface disposal as LLW, even though it is legally defined as LLW. The NRC's regulations in 10 CFR 61.55(a)(2)(iv) require that this type of waste be disposed of in a geologic repository unless approved for an alternative disposal method on a case-specific basis by the NRC (NRC 2002).

As listed in table 10, the total volume of Class A, Class B/C, and GTCC radioactive waste for disposal is estimated at 94,433.8 m3 (3,334,898 ft3) (OPPD 2023). Class A waste will be shipped to the EnergySolutions LLW disposal facility in Clive, Utah. Class B/C waste will be shipped to the Waste Control Specialists (WCS) LLW disposal facility in Andrews County, Texas. The GTCC waste will remain onsite in the FCS ISFSI. In May 2020, all spent nuclear fuel was transferred to the ISFSI, which will remain after decommissioning (OPPD 2021). The ISFSI is not included within the scope of the LTP, and under the LTP, the 10 CFR Part 50 operating license will be reduced to the ISFSI. The ISFSI will remain in operation until such time as a deep geologic repository becomes available to accept spent fuel or until other spent fuel disposal arrangements become available.

Table 10. Projected LLW Disposal Volumes Waste Class Volume (m3) Volume (ft3)

Class A Waste 94,365 3,332,476 Class B/C Waste 47.18 1,666 GTCC Waste 21.12 746 (Source: OPPD 2023)

Radioactive waste will be transported by truck or rail. To make sure areas at the site are not cross-contaminated during decommissioning, the OPPD has established dedicated waste haul routes (i.e., single-usage routes) for radioactive and nonradioactive waste (figure 7) which would mitigate the potential for contaminated material to come in contact with uncontaminated material. The OPPD will conduct decommissioning in accordance with its radioactive waste management program, process control program, health and safety program, RPP, and ODCM to manage the classification, processing, packaging, and removal of radioactive waste to meet the unrestricted release criteria.

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3.13.2 Nonradioactive Waste All concrete debris from the demolition of nonradiological structures will be removed from the site and disposed of at an offsite landfill or recycling facility. None of the concrete from demolition will be used as fill material for excavations or remaining basements. Fill material from the rail spur expansion will be used for backfilling basements as needed (OPPD 2023).

The majority of nonradioactive waste from decommissioning will result from removal of clean concrete and clean scrap metal. The OPPD will ship clean concrete and clean nonhazardous waste will to a local landfill and will recycle clean scrap metal.

Table 11 provides the projections of nonradioactive waste generated from the FCS decommissioning. The largest volume of nonradioactive waste is clean scrap metal.

Table 11. Projected Nonradioactive Waste Quantities Waste Type Disposal Method Volume (m3) Volume (ft3)

Clean Concrete Local landfill 70,735.1 2,497,987 Clean Nonhazardous Waste Local Landfill 1,477.7 52,184 Clean Scrap Metal Recycled 80,595.8 2,846,213 Totals 152,808.6 5,396,384 Source: OPPD 2021 3.13.3 Waste Management Direct and Indirect Impacts Decommissioning GEIS Determination Disposal of high-level radioactive waste is beyond the scope of the GEIS (NRC 2002).

Regarding LLW, the GEIS (Section 4.3.18) did consider the volume of land required for LLW disposal (NRC 2002). The GEIS estimated the volume of land required for radioactive waste disposal as an irretrievable and irreversible impact. In the GEIS (Table 4-7), it was estimated that for DECON (see footnote 4 of section 2.1), 8,000 to 10,000 m3 (282,500 to 353,000 ft3) of land would be needed for disposal of LLW for a PWR larger in plant size than the FCS based on previously decommissioned facilities. Because the volume of waste was underestimated for this site, the following section provides site-specific details used by the NRC staff to determine the impact of the FCS LLW disposal.

Site-Specific Activities As described in section 3.13, the volume of LLW being generated at the FCS, 94,433.8 m3 (3,334,898 ft3), is much greater than the volume of land assumed in the GEIS. Table 12 summarizes the estimated volumes of LLW waste going to each site, as well as each sites capacity. The OPPD will dispose of the FCS Class A waste at a facility operated by EnergySolutions with an overall LLW capacity of 6,670,051 m3 (235,550,619 ft3).

(EnergySolutions 2015). Therefore, the FCS Class A waste estimated volume of 94,365 m3 (3,332,476 ft3) represents approximately 1 percent of EnergySolutionss capacity for LLW.

The OPPD intends to dispose of Class B and C waste at a facility run by WCS) with a licensed disposal capacity of 736,238 m3 (26,000,000 ft3) (WCS 2022).

December 2023 3-37

Table 12. Summary of LLW Disposal Facilities and Capacities FCS LLW Volume for Percent of Capacity Needed Disposal Facility Capacity Disposal for the FCS Waste EnergySolutions 6,670,051 m3 94,365 m3 1.4 (235,550,619 ft3) (3,332,476 ft3)

WSC 736,238 m3 47.18 m3 6.4 x 10-3 (26,000,000 ft3) (1,666 ft3)

Source: WCS 2022 https://www.wcstexas.com/about/our-facilities/facilities/; accessed August 19, 2022.

The OPPD estimates generating 47.18 m3 (1,666 ft3) of Class B and C waste, which is a small fraction of WCSs capacity (approximately .006 percent). Therefore, because waste from the FCS represents such a small fraction of the overall capacity of both EnergySolutions and WCSs facilities, disposal of waste from the FCS would not create a noticeable impact on the capacity of the facilities at EnergySolutions or WCS.

The NRC staff concludes that although remaining decommissioning activities, site remediation, and final site radiological surveys are or will be generating a significant amount of LLW waste, the amount for decommissioning the FCS site would not have a noticeable effect on the overall disposal capacity at either facility. It is worth noting that as more nuclear reactors reach the end of their operating life, more LLW will be generated and will have a cumulative effect on disposal capacity. However, disposal capacity of LLW waste facilities would be evaluated at each of those environmental reviews.

The OPPD will continue to implement the RPP, Radioactive Waste Management Program, and ODCM to protect workers and the public during decontamination and decommissioning activities (OPPD 2021) to both reduce radiological waste and reduce dose.

The GEIS did not consider the impacts of nonradioactive waste generation, handling, and disposal. Based on the information provided in the LTP application, the NRC has evaluated the impacts of the generation, handling, and disposal of nonradioactive waste for the FCS.

Nonradioactive waste would be either disposed of at a local landfill or recycled. All waste generated or discovered on-site must be properly handled, contained, and disposed as per all applicable regulations, including Nebraska Title 128 - Nebraska Hazardous Waste Regulations and Nebraska Title 132 - Integrated Solid Waste Management Regulations. Specifically, demolition of site structures, construction of rail lines, containerization and shipping of radiological materials, generation and disposal of hazardous wastes etc. would require a No Waste Permit issued by the State (State of Nebraska, 2023). The NRC staff also assumes that any hazardous waste would be disposed of appropriately as required by local regulations. There are five landfills in Washington County and nearby Douglas County that accept construction and demolition waste (NE DEE 2017). The NRC staff expects that the OPPD will continue to adhere to applicable local, State, and Federal requirements regarding nonradioactive waste generation, handling, and disposal. Therefore, based on the availability of landfills, the NRC staff does not expect a noticeable impact on local landfill capacity from the decommissioning of the FCS.

3.14 Cumulative Effects The Council on Environmental Quality regulations that implement NEPA define cumulative effects as effects on the environment that result from the incremental effects of the action when added to the effects of other past, present, and reasonably foreseeable actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative December 2023 3-38

effects can result from individually minor but collectively significant actions taking place over a period of time. (40 CFR 1508.1). The NRC staff evaluated whether cumulative environmental effects could result from the incremental effects of the proposed action when added to the effects of other past, present, or reasonably foreseeable actions in the area.

Decommissioning and demolition activities at the FCS have been ongoing since 2019 and include the actions described in section 2.1.2 of this EA. In 2019, the NRC approved partial site releases of 48.6 ha (120 ac) and 192.2 ha (475 ac) parcels of land (Figure 3). Current and reasonably foreseeable future actions in the area include continued operation of the FCS ISFSI, continued use of the Missouri River by commercial barge and recreational boat traffic, presence of the Cargill agricultural facility, and implementation of activities (e.g., land use planning, transportation projects, etc.) described in the Washington County, Nebraska Comprehensive Development Plan (JEO 2017). Near the FCS site, in early 2023, completion of a new Dollar General distribution warehouse on the southside of Blair, Nebraska, is anticipated to employ approximately 400 people and support more than 1,500 stores in the Midwest (Crisler 2022).

The 74,322 m2 (800,000 ft2) facility will be located on 32 ha (85 ac) just off Highway 75 (Hamer 2021).

After FCS decommissioning is complete, most visible structures (e.g., auxiliary buildings, the containment structure, etc.) will have been demolished and removed. Exceptions are the ISFSI and IOF, which will remain onsite in accordance with OPPDs 10 CFR Part 72 general license associated with its 10 CFR Part 50 license. The onsite ISFSI is a passive facility that does not have any moving parts and requires minimum maintenance or management. Operation of the ISFSI includes minimal security and basic utility services that are already present. Doses to the public and workers are expected to remain within regulatory limits. Although the ISFSI will remain in place, it is situated several hundred meters (yards) from the banks of the Missouri River and would have a minimal impact on visual and scenic resources due the distance away from the riverside and small vertical height (compared to the FCS). Therefore, the NRC staff concludes that FCS decommissioning activities and the remaining onsite ISFSI would have a SMALL incremental contribution to cumulative impacts on visual and scenic resources when added to past, present, or reasonably foreseeable future actions.

The Missouri River will continue to be used for commercial barge traffic and recreational boating. The Missouri River has previously been heavily modified by U.S. Army Corps of Engineers actions to prevent meandering, including the installation of six dams upstream of the FCS. These upstream dams may have resulted in direct habitat loss as well as habitat degradation from changes in flow conditions. Additionally, continued boat traffic could have a negative impact through the introduction of invasive species as well as by degradation of water quality from boat emissions, exhaust, and accidental fuel spills. During decommissioning activities at the FCS, a lower volume of Missouri River water is withdrawn as compared to water withdrawal during operations because the FCS will no longer be withdrawing cooling water for the reactor systems. The NRC staff also anticipate future withdrawals would be minimal because of the reduced needs for water during decommissioning. Therefore, the NRC staff concludes that the FCS decommissioning activities would have a SMALL incremental contribution to cumulative impacts on ecological resources when added to past, present, or reasonably foreseeable future actions.

Washington County, Nebraska, county planners designed a Comprehensive Development Plan to guide orderly growth and development within the county for the location of future land developments and uses of land (JEO 2017). Future land development would be reflective of the specific land-use development types (i.e., policy areas) as defined in the plan. The four policy December 2023 3-39

areas included in the plan are (1) urbanized growth area, (2) agricultural, (3) transitional, and (4) urban reserve. The plan also recommends that future development uses, specifically in commercial and industrial, urban residential, and rural residential development types, be designed in ways to minimize impacts on the surrounding uses (i.e., cluster development, development away from environmentally sensitive conditions) and minimize sprawl (JEO 2017).

Based on the development direction in the plan, the existing surrounding areas being mostly agricultural, and OPPDs plan to release the FCS site for unrestricted use, thereby opening the land parcel up for future development, the NRC staff concludes that the FCS decommissioning activities would have a SMALL incremental contribution to cumulative impacts on land use when added to past, present, or reasonably foreseeable future actions. This is because releasing the land for unrestricted use will not interfere with future uses to which the land can be used.

In addition, the plan also identifies road improvement projects including resurfacing, grading, and road shoulder work within the county (JEO 2017). Some of the planned road improvement projects would be along Highway 75 near Blair (approximately 4.8 km [3 mi] away) (JEO 2017) and could alleviate additional truck traffic anticipated as a result of the new Dollar General distribution warehouse (Hamer 2021). These road improvement projects were planned for completion in 2022 and are anticipated to have minimal timing overlap with decommissioning activities at the FCS. Transportation of workers and materials to and from the FCS site may be minimally affected if road improvement projects overlap with daytime vehicle traffic related to decommissioning activities. Because any potential traffic volume would be temporary and minimal, the NRC staff concludes that the FCS decommissioning activities would have a SMALL incremental contribution to cumulative impacts on transportation when added to past, present, or reasonably foreseeable future actions.

The NRC staff has assessed the potential incremental impacts of the proposed action to the current and reasonably foreseeable activities discussed above and, for the reasons stated above, determined that there would be no significant cumulative effects because there would only be minimal incremental effects from the proposed action and minor overlapping effects with other projects described above.

3.15 Summary of Environmental Consequences Table 13 contains the impacts to those resource areas not addressed generically in the GEIS, and those resource areas that were found to be outside of the bounds of the discussion in the GEIS.

Table 13. Summary of Environmental Consequences Specifically Identified in the GEIS Environmental Resource Impacts Considerations Threatened and Decommissioning and license termination activities may affect but are not Endangered Species likely to adversely affect Federally listed threatened and endangered species.

Environmental Justice The NRC staff do not expect disproportionally high or adverse human health or environmental effects on minority or low-income populations living near the FCS.

December 2023 3-40

Environmental Resource Impacts Considerations Offsite Land Use There are no planned activities outside of the operational area, and the OPPD commits to use BMPs to protect adjoining offsite lands. Therefore, the impact on offsite land use is expected to be SMALL Historic and Cultural There are no planned activities outside of the operational area; therefore, the Resources beyond impact on historical and culture resources beyond the operational area is operational area expected to be SMALL Aquatic and Terrestrial There are no planned activities outside of the operational area. The OPPD Ecology beyond commits to obtaining all necessary licenses from Federal or State agencies operational area and to implementing BMPs to limit or prevent offsite ecological impacts.

Therefore, the impact to ecological resources beyond the operational area is expected to be SMALL Waste Management The estimated amount of LLW to be generated is larger than anticipated in the GEIS, however, it is a small fraction of the total capacity of the two waste disposal sites. The NRC staff does not expect the nonradioactive waste will be a meaningful amount for the local landfills available for disposal.

Therefore, the impacts of waste generation and management is expected to be SMALL December 2023 3-41

4 CONSULTATION AND COORDINATION 4.1 State Review On August 18, 2023, the NRC submitted the draft EA to the State Liaison Officer at the Nebraska Department of Health and Human Services for their review and comment (NRC 2023b). The Nebraska Department of Health and Human Services responded on October 12, 2023, with comments providing additional details on the State of Nebraskas applicable regulations for air quality, stormwater, water quality, and waste management which were incorporated in the final EA (State of Nebraska 2023).

4.2 National Historic Preservation Act Section 106 Consultation In an effort to identify potential cultural and historic resources, the NRC staff contacted 12 Federally recognized Native American Tribes with ancestral ties to the project area, requesting information about historic and traditional cultural properties (NRC 2022d). The 12 tribes included (1) the Apache Tribe of Oklahoma, (2) Iowa Tribe of Oklahoma, (3) Otoe-Missouria Tribe of Indians, (4) Omaha Tribe of Nebraska, (5) Cheyenne and Arapaho Tribes, (6) Iowa Tribe of Kansas and Nebraska, (7) Santee Sioux Nation, (8) Sac and Fox Tribe of the Mississippi in Iowa, (9) Winnebago Tribe of Nebraska, (10) Sac and Fox Tribe of Missouri in Kansas, (11) Sac and Fox Nation, and the (12) Ponca Tribe of Nebraska. The Winnebago Tribe of Nebraska responded, requesting to be kept informed of any discoveries of cultural resources during ground-disturbing activities (Winnebago 2022). The NRC staff sent a letter to the Ne SHPO on September 29, 2022, with a determination that no historic properties will be affected by the proposed action (NRC 2022c). The Ne SHPO responded on September 30, 2022, with its concurrence with NRC staffs determination (Ne SHPO 2022).

4.3 Endangered Species Act Section 7 Consultation Federal agencies may fulfill their obligations to consult with the FWS under ESA Section 7 in conjunction with the interagency cooperation procedures required by other statutes, including NEPA (50 CFR 402.06(a)). In such cases, the Federal agency should include the results of the ESA Section 7 consultation in the NEPA document (50 CFR 402.06(b)). The NRC considers this EA and associated correspondence with the FWS (FWS 2023a; FWS 2023c) to fulfill its obligations under ESA Section 7.

Upon receipt of OPPDs application, the NRC staff considered whether any Federally listed or proposed species or designated or proposed critical habitats may be present in the action area (as defined at 50 CFR 402.02) for the proposed action. As discussed in section 3.8 of this EA, the NRC staff found that the proposed action may affect, but is not likely to adversely affect, the Northern Long-eared Bat, Tricolored Bat, Piping Plover, Monarch Butterfly, and the Pallid Sturgeon. The NRC submitted the draft EA to the FWS for its review and concurrence with the staffs findings on August 18, 2023 (NRC 2023c). On November 5, 2023, the FWS concurred with the NRC determinations and provided no additional comments (FWS 2023c).

December 2023 4-1

5 CONCLUSIONS AND RECOMMENDATIONS The NRC has prepared this EA as part of its review of the FCS license amendment request to approve its LTP for the FCS in Washington County, Nebraska. If approved this license amendment request would also add a license condition to the FCS license reflecting NRCs approval of the LTP and establishing criteria for determining when changes to the LTP require prior NRC approval. The Decommissioning GEIS generically addressed many of the potential environmental impacts of decommissioning at the FCS. During its review of the FCS LTP, the NRC concluded that the impacts for most resource areasonsite land use; water resources; air quality; ecology, not including threatened and endangered species or outside the operational area; socioeconomics; historic and cultural resources within the operational area; aesthetics; noise; transportation; and nonradioactive waste managementwere still bounded by the GEIS.

Therefore, the NRC does not expect impacts associated with these issues beyond those discussed in the GEIS, which concluded that the impact level for these issues was SMALL.

In the GEIS, the NRC staff concluded that it could not necessarily determine the environmental impacts of decommissioning generically for six environmental resource areas. The GEIS concluded that two of these six resource areas (i.e., threatened and endangered species and environmental justice) must always be evaluated on a site-specific basis in site-specific EAs, such as this EA for the FCS LTP. Depending on the site-specific circumstances, the following four additional resource areas are considered to be conditionally site-specific: (1) offsite land use, (2) historic and cultural resources beyond the operational area with no current cultural and historic resource survey, (3) terrestrial ecology beyond the operational area, and (4) aquatic ecology beyond the operational area (NRC 2002).

The NRC evaluated the potential environmental impacts of the remaining decommissioning and license termination activities on the six environmental resource areas that cannot be determined generically: (1) threatened and endangered species, (2) environmental justice, (3) offsite land use, (4) historic and cultural resources, (5) terrestrial ecology beyond the operational area, and (6) aquatic ecology beyond the operational area. The NRC did not identify any significant impacts identified for any of these resource areas. In addition, topics not included in the GEIS that the NRC staff evaluated in this EA include the affected environment, climate change, cumulative impacts, contamination of groundwater from decommissioning activities, and nonradioactive waste management.

On the basis of the findings discussed in this EA, the NRC has concluded that there are no significant environmental impacts and a Finding of No Significant Impact is appropriate. That finding will be published in the Federal Register.

December 2023 5-1

6 LIST OF PREPARERS This EA was prepared by the Environmental Center of Expertise in the Division of Rulemaking, Environmental, and Financial Support in the Office of Nuclear Material Safety and Safeguards.

Contributors to the EA are listed below.

Contributor Years of Experience, Education Stacey Imboden

• BS Meteorology

• MS Environmental Engineering

• Duke NEPA Certificate

• 21 years of professional experience Jill Caverly

• BS Civil Engineering

• MS Civil Engineering

• 30 years of professional experience Peyton Doub

• BS Plant Sciences (Botany)

• MS Plant Physiology (Botany)

• Duke NEPA Certificate

• Professional Wetland Scientist

• Certified Environmental Professional

• 30 years of experience in terrestrial and wetland ecology and NEPA Nancy Martinez

• BS Earth and Environmental Science

• AM Earth and Planetary Science

• 11 years of experience in environmental impact analysis Marla Morales

• BA Geology

• MS Geology

• License- Professional Geoscientist - States of Virginia and Texas

• Shipley Group NEPA Certificate

• 15 years of environmental site analysis and evaluations Isaac Johnston

• BS Marine Science

• PhD Environmental Engineering and Earth Sciences

• 1 year of professional experience December 2023 6-1

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OPPD (Omaha Public Power District). 2019. Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report. Omaha, Nebraska. ADAMS Accession No. ML19351E355.

December 2023 7-5

OPPD (Omaha Public Power District). 2020a. Response for Fort Calhoun Station Re: Fort Calhoun Station, Unit No. 1, Revised Post-Shutdown Decommissioning Activities Report.

Omaha, Nebraska. ADAMS Accession No. ML20202A654.

OPPD (Omaha Public Power District). 2020b. Fort Calhoun Station Unit No. 1, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of all Spent Fuel Assemblies from the Spent Fuel Pool. Washington, D.C. ADAMS Accession No. ML20139A138.

OPPD (Omaha Public Power District). 2021. License Amendment Request 21-01: Revised Fort Calhoun Station License to Add License Condition 3.D to Include License Termination Plan Requirements. Omaha, Nebraska. ADAMS Accession No. ML21271A178.

OPPD (Omaha Public Power District). 2022. Response to Fort Calhoun Station, Unit No. 1 -

Review of License Termination Plan Requirements - Request for Additional Information.

Omaha, Nebraska. ADAMS Accession No. ML22167A199.

OPPD (Omaha Public Power District). 2023. Review Of License Amendment Request To Add License Condition To Include License Termination Plan Requirements - Request For Additional Information. Omaha, Nebraska. ADAMS Accession No. ML23060A197.

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<https://data.census.gov/cedsci/table?g=0500000US31055,31153,31177&y=2020&d=DEC%20 Redistricting%20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P1> (Accessed 13 July 2022)

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THPO Office, Angel De Cora Museum, Little Priest Tribal College. Winnebago, Nebraska.

ADAMS Accession No. ML22222A119.

December 2023 7-7