ML093010071

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Environmental Assessment Related to License Amendment of License No. DPR-13
ML093010071
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 11/20/2009
From: Mcconnell K
Division of Decommissioning, Uranium Recovery and Waste Programs
To:
San Diego Gas & Electric Co, Southern California Edison Co
VAALER M
References
Download: ML093010071 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY DOCKET NO. 50-206 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 ENVIRONMENTAL ASSESSMENT RELATED TO ISSUANCE OF A LICENSE AMENDMENT FOR U.S. NUCLEAR REGULATORY COMMISSION LICENSE NO. DPR-13 Summary The U.S. Nuclear Regulatory Commission (NRC) is issuing an environmental assessment (EA) and finding of no significant impact (FONSI) regarding a partial site release from license No. DPR-13 for the San Onofre Nuclear Generating Station, Unit 1 (SONGS-1), issued to the Southern California Edison Company (SCE, the licensee) at the San Onofre Nuclear Generating Station (SONGS) facility in San Clemente, California. The EA and FONSI set forth in this document are available on November 30, 2009 (74 FR 62605).

Introduction and Site Description The NRC staff has prepared an EA of SCEs request for a partial site release of the Circulating Water System (CWS) for SONGS-1 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML080580468). The SONGS facility is located approximately 4 miles south of San Clemente, California. SONGS-1, Docket No. 50-206, was a Westinghouse 456 megawatt electric (MWe) pressurized water reactor which was granted Facility Operating License No. DPR-13 on January 1, 1968 (ADAMS Accession No. ML13309A138), and ceased operation on November 30, 1992 (ADAMS Accession No. ML13319B040). The licensee completed defueling on March 6, 1993 (ADAMS Accession No. ML13319B055), and maintained the unit in SAFSTOR (i.e., deferred dismantlement) with the intent of decommissioning the entire site when SONGS, Units 2 and 3 ceased operation. On December 28, 1993 (ADAMS Accession No. ML13319B059), the NRC approved the Permanently Defueled Technical Specifications for SONGS-1.

SCE submitted the proposed Decommissioning Plan for SONGS-1 on November 3, 1994 (ADAMS Accession No. ML13319B073). As a result of the 1996 revision to the regulations in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.82, the NRC replaced the requirement for a decommissioning plan with a requirement for a Post Shutdown Decommissioning Activities Report (PSDAR). On August 28, 1996, the SONGS-1 Decommissioning Plan became the SONGS-1 PSDAR (61 FR 67079; December 19, 1996). On December 15, 1998 (ADAMS Accession No. ML13184A353), SCE submitted an update to the PSDAR to the NRC, as required by 10 CFR 50.82(a)(7), in order to begin planning for the dismantlement and decommissioning of SONGS, Unit 1.

In June 1999, SCE initiated the prompt decommissioning of SONGS-1 (i.e., DECON) (ADAMS Accession No. ML13319B111). At that time, the onshore activities for dismantlement of the CWS at SONGS-1 were already underway. In December 2007, SCE submitted a request to release for unrestricted use a parcel of the ocean bottom leased from the California State Lands Commission (CSLC) and the offshore portion of the SONGS-1 CWS remaining beneath that parcel of ocean bottom.

SCE conducted characterization surveys of the SONGS-1 components and CSLC lease area that are subject to the partial site release and identified low concentrations of radioactive cesium, cobalt, and sodium in the sediments surrounding the SONGS-1 CWS. These concentrations result in a total calculated dose to the public of less than 1 millirem per year (mrem / yr), which is below the NRC unrestricted use release limit of 25 mrem / yr.

The NRC staff evaluated SCEs request to release the offshore portion of the SONGS-1 CWS and developed this EA to support the review of SCEs proposed license amendment request associated with the partial site release, in accordance with the requirements of 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, and 10 CFR 50.83, Release of part of a power reactor facility or site for unrestricted use. Based on the staffs evaluation, the conclusion of the EA is a FONSI on human health and the environment for the proposed licensing action and associated partial site release of the SONGS-1 CWS, as described in more detail below.

Description of the Proposed Action The proposed action would amend NRC License No. DPR-13 to approve the release for unrestricted use of the offshore portion of the SONGS-1 CWS structures, as well as the land leased from the CSLC beneath which these structures lie. SCE has isolated this portion of the CWS from the rest of the SONGS-1 plant and remaining systems and will abandon it in place.

No other actions are planned as part of the proposed license amendment.

The affected area is described in a lease agreement between the State of California, acting by and through the CSLC, SCE, and the San Diego Gas and Electric Company. The lease, which commenced on September 24, 1964, is identified as Lease No. PRC 3193.1 and describes a piece of tide and submerged land approximately 100 feet wide by 3,310 feet long extending across the ocean floor in roughly a southwesterly direction from the SONGS seawall. The components within the described piece of land that will be abandoned in place include:

1. The intake terminal structure extending 3,200 feet southwest of the seawall.
2. The intake conduit running from the intake terminal structure to the southwestern edge of a concrete plug installed in the intake stop gate structure within the SONGS-1 area.
3. The discharge conduit running from the southwest edge of the concrete plug installed in the intake stop gate structure within the SONGS-1 area to the discharge terminal structure.
4. The discharge terminal structure extending 2,600 feet southwest of the seawall.

The intake and discharge conduits are both 12 feet in diameter. At the point where they connect to the (onshore) stop gate structures within the SONGS-1 area, the top of each conduit is 12 feet below Mean Lower Low Water (-12 MLLW).

The intake conduit extends 3,200 feet to the intake terminal structure where the top of the conduit is approximately -32 MLLW. The intake conduit is below the ocean floor and was covered by nominally four feet of sand along its length when originally constructed.

The discharge conduit extends 2,600 feet to the discharge terminal structure where the top of the conduit is approximately -28 MLLW. The discharge conduit is also below the ocean floor and was covered by nominally four feet of sand along its length when initially constructed.

The intake and discharge conduits were constructed with access ports in the form of manholes.

The first access port is 700 feet from the SONGS seawall. Additional manholes are spaced at approximately 500 foot intervals beginning 700 feet southwest of the seawall (a total of five access ports on the intake conduit and four access ports on the discharge conduit). The associated manhole covers rise approximately four feet above the ocean bottom and have not been opened since installation of the conduits.

Need for the Proposed Action The purpose of the proposed action is to reduce residual radioactivity in and around the CWS at the SONGS-1 facility to a level that permits release of the property for unrestricted use. The NRC is fulfilling its responsibilities under the Atomic Energy Act, as amended, to make a decision on a proposed license amendment for the partial site release of the SONGS-1 CWS in a manner that ensures protection of the public health and safety and the environment.

Safety Evaluation of the Proposed Action The NRC staff evaluated the safety impacts of the proposed action to release the SONGS-1 CWS for unrestricted use and concludes that the requirements of 10 CFR Part 51, 10 CFR 50.83, and other applicable NRC regulations have been satisfied (ADAMS Accession No. ML092670125).

Environmental Impacts of the Proposed Action The NRC staff has reviewed the request for unrestricted release of the CWS for the SONGS-1 facility and examined the environmental impacts of the partial site release of the SONGS-1 CWS. Based on its review, the staff has determined that the affected environment and the environmental impacts associated with the partial site release of the SONGS-1 CWS are bounded by the impacts evaluated in the "Generic Environmental Impact Statement (GEIS) in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities" (ADAMS Accession No. ML042310492). This GEIS analyzes regulatory alternatives for establishing radiological criteria for decommissioning structures and lands of licensed facilities. The staff also finds that the proposed partial site release of the SONGS-1 CWS complies with 10 CFR 20.1402, Radiological criteria for unrestricted use.

Based on its evaluation of the licensees partial site release application and supporting documentation, the NRC staff concludes that the SONGS-1 facility has adequate radiation

protection procedures and capabilities, and has implemented an acceptable program to keep exposure to radioactive materials as low as reasonably achievable (ALARA). As noted above, SCE has prepared a plan for the partial site release of the CWS describing the work to be performed, and work activities are not anticipated to result in a dose to workers or the public in excess of the limits set forth in 10 CFR Part 20, Standards for Protection Against Radiation.

Past staff and industry experiences with partial site releases indicate that public and worker exposure will be far below the limits found in 10 CFR Part 20.

The NRC has determined that the proposed release of the SONGS-1 CWS is primarily procedural and administrative in nature now that the CWS no longer serves a safety function for the plant, and that the licensee has no safety, physical security, or emergency preparedness need to retain the CWS. The environmental impacts associated with the shutdown power reactor will not change as a result of the proposed release of the SONGS-1 CWS. The proposed release will not result in any additional public or environmental exposure to radioactive contamination, nor will the calculated dose to the public approach the NRC unrestricted use release limit of 25 mrem / yr as a result of the release of the SONGS-1 CWS. Therefore, there are no significant radiological environmental impacts associated with the proposed action.

With regard to potential non-radiological impacts, the proposed release of the SONGS-1 CWS from NRC jurisdiction does not involve or authorize any construction activities, renovation of buildings or structures, ground disturbing activities or other alteration to land. The proposed release of the SONGS-1 CWS will not result in any change to current licensed activities on that portion of the site that will remain under NRC jurisdiction, and therefore will not result in any changes to the workforce or vehicular traffic. Furthermore, as the NRC has determined that the proposed release of the SONGS-1 CWS is an administrative action, it is not a type of activity that has the potential to cause effects on historic properties or cultural resources, including traditional cultural properties. Similarly, the NRC staff has determined that the proposed release of the SONGS-1 CWS will have no effect on listed species or critical habitat. In addition, the proposed release of the SONGS-1 CWS will not result in any changes to non-radiological plant effluents and thus, will have no impact on either air or water quality. Therefore, there are no significant non-radiological environmental impacts associated with the proposed action.

Accordingly, the NRC staff concludes that there are no significant environmental impacts associated with the proposed action to release the SONGS-1 CWS for unrestricted use.

Environmental Impacts of Identified Future Activities Long-term disposition of the offshore portion of the SONGS-1 CWS involves removal of the vertical structures and navigational marker buoys at the offshore terminus of the intake and discharge conduits to eliminate the risk of navigation hazards. The nine near-shore manhole risers along the intake and discharge conduits will also be removed. The onshore portion of the intake and discharge conduits (the portion from the seawall to MLLW) will be plugged with concrete. The offshore portion of the intake and discharge conduits would remain buried under the seafloor beneath approximately 5 feet (1.5 meters) of sand.

Sand and ocean bottom sediment will be side cast in the immediate vicinity of the vertical structures to expose the intake and discharge conduits. Once the vertical structures and manhole risers are removed, prefabricated metal barriers will be installed that will preclude access by marine mammals and divers while allowing sand and sediment to gradually backfill

the intake and discharge conduits. This movement of sand and sediment will fill the intake and discharge conduits in the immediate area of the access points as well as sealing off the access points themselves. Once the access points are covered with sand and sediment, exposure to the residual activity in the intake and discharge conduits will be reduced virtually to zero. Any residual licensed radioactive material will be effectively entombed.

Because these identified future activities are beyond the scope of SCEs current partial site release request, they were not analyzed in this EA by the NRC staff. However, the CSLC evaluated these actions in detail in the Disposition of Offshore Cooling Water Conduits, SONGS Unit 1 Final Environmental Impact Report (EIR), and determined that the proposed project with specified controls is environmentally acceptable (see the EIR at California State Clearinghouse No. SCH 2004061092, dated June 2005).

Environmental Impacts of the Alternatives to the Proposed Action The no action alternative to the partial site release of the SONGS-1 CWS is to leave the system as is, and maintain it within the current NRC license for SONGS-1. The no action alternative is not acceptable to the staff because it will result in a violation of the NRCs Decommissioning Timeliness Rule outlined in 10 CFR 30.36, Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas, which requires licensees to begin to decommission their facilities when licensed activities cease. The no action alternative would also prevent SCE from ending its lease with the CSLC and require that it be renewed, an action within the purview of the State of California. In addition, SCE would be required to pay annual rent to the CSLC and maintain the mandated financial assurance. There is no difference in potential impacts on the environment between this alternative and the proposed action Another alternative is to leave the intake and discharge conduit piping as is for potential future uses (e.g., a desalination plant), but terminate the NRC license for that portion of the SONGS-1 facility. Not removing the manhole covers for the intake and discharge conduits would preclude divers from entering the pipes except at the terminals and reduce the calculated radiological dose to personnel for the proposed action. Any future use of the pipes would require an evaluation of the potential environmental impacts and approval by the CSLC at that time.

Because this and other potential future alternatives are beyond the scope of SCEs current partial site release request, they were not analyzed in this EA by the NRC staff. However, the CSLC evaluated this and several other alternatives for removal of the SONGS-1 CWS, including removal of portions of the system closest to the beach, and crushing the pipe in place, as a part of their EIR. The CLSC determined that the proposed alternative with specified controls is environmentally acceptable. Therefore, as there is no policy or regulatory reason for the NRC to require a licensee to retain property for which the licensee has no further operational need, additional alternatives were not further considered.

Agencies and Persons Consulted This EA was prepared by James Shepherd, NRC Project Engineer, Reactor Decommissioning Branch, and coordinated with the CSLC. The NRC staff determined that the proposed action is not a type of activity that has the potential to cause effects on historic properties because the proposed action is purely administrative and will not affect any physical property. The proposed action also provides CSLC with sole jurisdiction over the area. Therefore, no further

consultation is required under Section 106 of the National Historic Preservation Act. The NRC staff also determined that Section 7 consultation under the federal Endangered Species Act is not required because the proposed action is purely administrative in nature and will not affect the physical environment. The NRC staff provided a draft of its EA to the CSLC for review. The CSLC responded by letter dated October 26, 2009, with proposed modifications. Following discussions to clarify the comments, the NRC incorporated them into this EA.

Conclusion The NRC staff has concluded that the proposed action will not significantly impact the quality of the human environment, and that the proposed action is the preferred alternative. The NRC staff has determined that the proposed action complies with 10 CFR Part 20. No radiologically contaminated effluents are expected during the partial site release of the SONGS-1 CWS. Occupational doses to workers involved with the partial site release of the SONGS-1 CWS are expected to be low and well within the limits of 10 CFR Part 20. No radiation exposure to any member of the public is expected, and public exposure will also be less than the applicable public exposure limits pursuant to 10 CFR Part 20.

The NRC staff has prepared this EA in support of its review of the proposed license amendment for the partial site release of the SONGS-1 CWS for unrestricted use by SCE. Based upon the analysis contained in this EA, the NRC finds that there are no environmental impacts from the proposed action that would have a significant effect on the quality of the human health and the environment, and that preparation of an environmental impact statement is not warranted.

Accordingly, the NRC has determined that a finding of no significant impact is appropriate. In accordance with 10 CFR 51.32(a)(4), this FONSI incorporates this EA by reference.

Dated at Rockville, Maryland, this 20th day of November 2009.

For the Nuclear Regulatory Commission.

/RA/

Keith I. McConnell, Deputy Director, Decommissioning and Uranium Recovery Licensing Directorate, Division of Waste Management and Environmental Protection, Office of Federal and State Materials and Environmental Management Programs.