ML13309A131

Environ Assessment Re Conversion of Provisional OL to full-term OL

ML13309A131
Person / Time
Site:	San Onofre
Issue date:	09/16/1991
From:	Office of Nuclear Reactor Regulation
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ML13309A129	List: ML13309A127 ML13309A130 ML13309A131
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NUDOCS 9109300206
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 ENVIRONMENTAL ASSESSMENT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO THE CONVERSION OF THE PROVISIONAL OPERATING LICENSE TO A FULL-TERM OPERATING LICENSE SOUTHERN CALIFORNIA EDISON COMPANY AND THE SAN DIEGO GAS AND ELECTRIC COMPANY SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1 DOCKET NUMBER 50-206 DATE:

September 16, 1991 9109300206 910916 PDR ADOCK 05000206 P

PDR

TABLE OF CONTENTS Page

1.0 INTRODUCTION

................................................... 1 2.0 THE SITE....................................................... 2 2.2 Regional Demography....................................... 2 2.3 Historical and Archeological Sites........................ 2 2.5 Surface and Ground Waters................................. 3 2.7 Ecology................................................... 3 3.0 THE PLANT...................................................... 6 3.3 Plant Water Use...........................................

7 3.4 Heat Dissipation Systems.................................

7 4.0 ENVIRONMENTAL EFFECTS OF SITE PREPARATION AND PLANT AND TRANSMISSION FACILITIES CONSTRUCTION......................... 8 5.0 ENVIRONMENTAL EFFECTS OF OPERATION OF THE PLANT................ 8 5.1 Impacts of Land Use..................................... 8 5.2 Impacts of Water Use.................................... 8 5.8 Impacts on Legally Protected Species...................... 13 6.0 ENVIRONMENTAL MEASUREMENT AND MONITORING PROGRAM............... 14 7.0 RADIOLOGICAL EFFECTS......................................... 14 7.1 Changes to the Plant.................................... 15 7.2 Summary of Radioactive Effluents and Exposures............ 16 7.3 Radiological Conclusion................................. 18 8.0 IMPLICATION OF THE PROJECT................................... 18 8.1 The Requirement for Power................................ 18 8.2 Social and Economic Effects.............................. 18 9.0 ALTERNATIVES TO THE PROJECT.................................. 19 10.0 BENEFIT-COST ANALYSIS........................................ 19 11.0 AGENCIES AND PERSONS CONSULTED................................ 20 12.0 BASIS AND CONCLUSION FOR NOT PREPARING AN FES SUPPLEMENT........ 20 i

1.0 INTRODUCTION

The San Onofre Nuclear Generating Station, Unit 1 (SONGS 1), is located in San Diego County, California, on the the Pacific Coast, about 100 kilometers (62 miles) southeast of Los Angeles, California, and about 82 kilometers (51 miles) northwest of San Diego, California. SONGS 1 is one of three nuclear generating stations located on the 87 hectare (215 acre) site. The San Onofre Nuclear Station, Unit 2 (SONGS 2) and the San Onofre Nuclear Station, Unit 3 (SONGS 3), each rated at 3390 MWt, are located adjacent to and immediately south of SONGS 1. The site, containing all three power stations and the associated parking, administrative, service, and support facilities, is located entirely within the United States Marine Corps (USMC)

Base, Camp Pendleton, near the northwestern end of Camp Pendleton's 29 kilometer (18 mile) shoreline.

On March 27, 1967, the Atomic Energy Commission's (AEC's or the Commission's) Directorate of Licensing (the staff), issued Provisional Operating License No. DPR-13 to Southern California Edison Company (SCE) jointly with the San Diego Gas and Electric Company (SDG&E) for SONGS 1.

The license allowed operation at power levels up to 1,347 MWt, 430 MWe (net). Since that time, SONGS 1 has operated up to that power level.

On August 31, 1972, SCE and SDG&E (the licensee) submitted to the Director of Regulation, "San Onofre Nuclear Generating Station Unit 1, Applicants' Environmental Report, Operating License Stage, Volumes I and II," (Ref. 1) in accordance with Section A of revised Appendix D (currently known as 10 CFR Part 51) of 10 CFR Part 50.

In the early 1970s, the Commission revised Appendix D to further require that the Director of Regulation, or his designee, analyze the report, and prepare a detailed statement of environmental considerations. Responding to that guidance, the staff issued a Final Environmental Statement (FES)

(Ref. 2) related to the operation of SONGS 1 in October 1973.

The proposed action is the conversion of Provisional Operating License (POL)

No. DPR-13 to a full-term operating license (FTOL) ef'ective for 40 years from the date of issuance of the construction permit %March 2, 1964).

The staff issued the 1973 FES to support this proposed conversion. However, the license conversion process was delayed because of the inception of the systematic evaluation program (SEP).

The SEP is an NRC staff program to review the designs of older operating nuclear plants to reconfirm and document their adherence to current safety requirements.

In a letter of November 5, 1982 (Ref. 3), the licensee was requested to review the SONGS 1 FES and update the findings and conclusions contained in the 1973 document.

-2 In a letter of February 5, 1986 (Ref. 4), the licensee responded to the staff's request, transmitting a report that documents significant changes to the SONGS 1 facility or the environs that could affect the conclusions in the SONGS 1 FES. The staff has reviewed the 1973 FES and the licensee's February 5, 1986, submittal, conducted an extensive site visit, and met with appropriate federal and state regulatory and resource agencies. The staff concluded that the FES should be updated. This document updates the October 1973 FES for SONGS 1, addressing only those sections of the FES that have been altered. The section and subheading numbers and titles in this document follow the 1973 FES. Where new material is added within major sec tions and was judged to warrant a separate subheading, the numbers begin after the last subheading contained in the 1973 FES for the appropriate section.

Radiological environmental effects are addressed in several sections of the 1973 FES. The major radiological discussions are included in Sections 3.5, Radioactive Waste Systems; 5.4, Radiological Impacts on Man; 5.7, Transportation Impacts; and 7.0, Environmental Effects of Accidents. This document consolidates the discussion of radiological effects into one section, Section 7.0.

2.0 THE SITE SONGS 1 was constructed on 6.5 hectares (16 acres) of the applicant's original 34 hectare (84 acre) easement from the USMC Base, Camp Pendleton.

Since the staff issued the FES, the licensee has added an adjoining 4.6 hectare (11.4 acre) parking area to the north of the original site and a 49 hectare (120 acre) area immediately east of the site on the other side of Interstate Highway 5 (the San Diego Freeway), abandoned U.S. Highway 101, and the Atchison, Topeka, and Santa Fe Railroad Line. The 4.6 hectare (11.4 acre) blacktop parking area provides parking for station personnel, and the 49 hectare (120 acre) parcel, named the Mesa Area by the licensee, provides administration, training, maintenance, and other miscellaneous facilities to the San Onofre site. Transmission rights-of-way leaving the site have not been changed since the 1973 FES, although additional circuits have been added.

2.2 Regional Demography The 1973 FES described a military housing complex being developed approximately 3 kilometers (2 miles) northwest of the site. The complex was planned for approximately 1,150 family units. The licensee has informed the staff (Ref. 4) that the military housing complex, San Onofre Heights, contains only 600 family units. The San Onofre mobile home park located about 0.8 kilometers (0.5 miles) south of San Onofre Heights contains a total of 140 units.

-3 The nearest population centers and their 1990 populations (Ref. 16) are San Clemente (41,100), 6 kilometers (4 miles) northwest; Mission Viejo (72,820), 16 kilometers (10 miles) northwest; San Juan Capistrano (26,183),

16.9 kilometers (10.5 miles) northwest; the coastal city of Oceanside (128,398), 27 kilometers (17 miles) southeast; and San Diego (1,110,549),

82 kilometers (51 miles) southeast. Population estimates for the USMC Base, Camp Pendleton vary between 32,000 and 36,000 personnel.

2.3 Historical and Archeological Sites In the 1973 FES, the staff identified several historical sites in the general vicinity of SONGS 1. The closest is Las Flores Adobe, which is inside Camp Pendleton about 12 kilometers (7.5 miles) from the San Onofre site and is included in The National Register of Historic Places. Two old Spanish missions are in the area: Mission San Juan Capistrano is 21 kilometers (13 miles to the north, and Mission San Luis Rey is 39 kilometers (24 miles) to the south. None of these sites has been affected by the construction and operation of SONGS 1. No new historical sites have been designated since the staff issued the FES.

2.5 Surface and Ground Waters 2.5.1 Storm runoff Storm runoff from the site has been extensively modified since issuance of the FES. Additionally, the licensee established runoff control for the new parking area north of the site and for the Mesa Area to the east.

Yard runoff from the facility flows through an oil-water separator and is discharged into the circulating water discharge line of Unit 1. The licensee installed a large concrete storm runoff ditch (North Ditch) that collects water from the northeastern edge of the restricted area, channels it northward and westward, and discharges it into the Pacific Ocean. This diversion protects the site from the probable maximum flood.

Surface water from the 4.6 hectare (11.4 acre) parking area is diverted to either the North Ditch or to the western margin of the parking area and through corrugated metal pipe to the beach area and into the Pacific Oceax.

Runoff from the Mesa Area is diverted to a debris basin located on the northern edge of the site. The debris basin empties into San Onofre Creek located north of the Mesa Area. The San Onofre Creek flows into the Pacific Ocean north of the site.

During the recent site visit, the staff verified that the licensee uses best management practices to control erosion and runoff from all three areas and to minimize sedimentation of the San Onofre Creek.

-4 Oceanography The licensee continues to perform physical and chemical monitoring of the marine environment offshore of San Onofre since the staff issued the 1973 FES. The information collected is summarized in the licensee's annual environmental reports (Ref. 5 and 6) and by the Marine Review Committee (MRC) (Ref. 7).

Since 1973, the licensee has developed a more accurate understanding of the long-term physical and chemical characteristics of the Pacific Ocean in the vicinity of the facility. This information has enabled the licensee to refine its database but does not represent a significant change from the data presented in the 1973 FES.

2.7 Ecology 2.7.1 Terrestrial Ecology In 1975-76, the licensee last conducted a terrestrial survey of the site area. The staff summarized the results of the study in Section 2.5.1 of the FES for Units 2 and 3 (Ref. 8) as partially summarized below.

The licensee conducted terrestrial ecological studies on a 0.61 hectare (1.5 acre) quadrant located immediately south of the site. In the monitoring program, the licensee documented seasonal changes in the biotic communities over a 1-year period.

About 80 percent of the study area is in a natural plant community of coastal sage scrub, and the remaining 20 percent has been disturbed by human activities. Total cover by vegetation on the study area ranged from 81 to 98 percent. The greatest cover was found in February, decreasing toward midsummer. The licensee found little vegetative diversity in the coastal sage scrub community, with California sagebrush, Artemisia californica, being the dominant specie (65 percent relative cover). Coyote bush, Baccharis pilularis, ranked second in the study area (9 percent relative cover), but had higher relative cover in the disturbed areas than in the climax stand. The licensee's survey suggested that surface disturbances significantly alter the composition of the coastal safe scrub community by encouraging the invasion of exotic perennial and annual plant species, especially mustards and grasses. These plants grew only in areas that have been disturbed (Ref. 9).

The licensee observed no endangered plant species, as expected for this very small study area (0.61 hectare) (1.5 acre).

The licensee observed various fauna within the study area, including 5 species of reptiles, 12 species of mammals, and 36 species of birds. No amphibians were sighted.

2.7.2 Aquatic Ecology To comply with the conditions contained in the California Coastal Zone Conservation Commission permit (Permit No. 183-73) issued February 28, 1974,

-5 for the construction of SONGS 2 and 3, an extensive ecological study of the marine environment offshore from San Onofre was begun by the licensee. The purpose of the study was to predict and later attempt to measure the effects of SONGS 2 and 3 on the marine environment. The licensee conducted the study in a manner that resulted in the broadest possible consideration of the effects of all three units on the entire marine environment in the vicinity of San Onofre. The study design and execution was controlled by the MRC consisting of three persons with professional experience in marine biology. One member was chosen by the applicant, one by the intervenors, and one by the California Coastal Zone Conservation Commission. Since 1974, the MRC has issued 21 reports (see Appendix A) including the final report on the marine environment offshore of the San Onofre Nuclear Generating Station.

As a result of these studies, the Southern California Bight in the vicinity of San Onofre is probably one of the best characterized stretches of Pacific coastline. The above referenced reports provide detailed descriptive information on the distribution, abundance, and variability of aquatic organisms inhabiting the marine environment in the vicinity of the facility. The licensee performed the studies to determine the effect of operating the station on the nearby San Onofre giant kelp bed, the effect of impingement and entrainment on 23 bight-wide adult fish stocks, and the effect of plant operation on sediment transport in the vicinity of the discharge structures.

The San Onofre giant kelp bed is located 2 kilometers (1.2 miles) offshore and largely south (0.5 to 2 kilometers (0.3 to 1.2 miles) of the SONGS discharge diffusers. The kelp plants, Macrocystis pyrifera, are anchored by holdfasts to the boulder and cobble substrate on the ocean floor and have fronds that reach to the ocean's surface. The kelp bed is a valuable commercial resource, providing commercial harvesting of the top several meters of the fronds, and providing protective habitat for hundreds of species of plants, fish, and invertebrates, including sea urchins, kelp bass, and other species. The size of the kelp beds varies over time. In 1980, the San Onofre kelp bed covered about 15.8 hectares (39 acres)

(Ref. 5). In early 1989, the kelp bed covered 63.8 hectares (158 acres)

(Ref. 5).

The effects of impingement and entrainment were studied for a number of species in the Southern California Bight. The MRC sponsored studies and evaluated the queenfish, Seriphus politus; white croaker, Genyonemus lineatus; California grunion, Leuresthes tenuis; black croaker, Cheilotrema saturnum; California corbina, Menticirrhus undulatus; and the jacksmelt, Atherinopsis californiensis.

Operation of the San Onofre station discharges warmed inshore water farther offshore of the facility. The MRC evaluated the effects on benthic organisms of discharging this inshore water, which may differ in sediment loading, to offshore regions. Reduction in light transmissivity was measured to determine the effect on giant kelp. The effect of station operation on soft benthos in the vicinity of SONGS was investigated. In the

-6 MRC-directed studies, researchers identified over 600 species of invertebrates, the most common groups being worms (polychaetes) and crustaceans. The great majority of species were rarely found in samples.

2.7.3 Legally Protected Species The licensee has a program to determine if the company's actions could disturb or destroy legally protected plant and animal species within the company's service area.

Aquatic Species The licensee evaluated the results of extensive impingement sampling at SONGS 1 and determined that the only protected species taken by the facility are harbor seals, Phoca vitulina, and California sea lions, Zalophus californianus. Both are protected under the Marine Mammal Conservation Act ot 1972, as amended. Since 1979, the licensee has collected 13 individuals at SONGS 1, and has returned all live individuals to the sea. Since 1982, Units 2 and 3 have collected 6 individuals, including harbor seals, California sea lions, and an occasional green sea turtle, Chelonia mydas.

The green sea turtle is listed as threatened under the Endangered Species Act of 1973, as amended. Although no green sea turtles have been impinged at Unit 1, the potential for future capture is present.

No other aquatic species that are protected by either State or Federal laws and that could be affected by the continued operation of Unit 1 are known to exist in the vicinity of the station. There is no identified critical marine habitat near the facility.

Terrestrial Species The licensee knows of no currently listed threatened or endangered species from the SONGS site. However, one species of bird, the California gnatcatcher, Polioptila californica, is under review for Federal listing.

The gnatcatcher is expected to occur on site, in the coastal sage scrub habitat to the south of Units 2 and 3 and around facilities located at the Mesa Area. Two State and Federally endangered species, the California least tern, Sterna antillarum browni and the least bell's vireo, Vireo bellii pusillus, are known to occur nearby. The California least tern is not known to nest on the SONGS site. However, they have been observed near the kelp beds offshore. The least bell's vireo, normally found in dense willow habitat, has been sighted on San Mateo Creek, north of the site, about 0.75 miles upstream from the San Diego Freeway.

The California brown pelican, Pelecanus occidentalis californicus, listed as endangered by both the State and Federal governments, is found along the coast. However, it only uses the site occasionally.

The California red-legged frog, Rana aurora draytoni, a State of California species of concern and a Federal candidate species, inhabits freshwater

-7 marshes, coastal estuaries, or slow moving freshwater streams. Suitable habitat is known to occur in the coastal wetlands similar to those found near the site. No specimens have been reported in the vicinity of the site.

The golden eagle, A uila chrysaetos, a species that is of special concern and is protected by te State of California, is known from the areas crossed by the transmission rights-of-way. The licensee has a program to protect the nests of this species and of raptors in general.

3.0 THE PLANT The licensee has made significant changes to the San Onofre site since the staff issued the FES. The licensee constructed two additional units, SONGS 2 and SONGS 3, in the area immediately south of SONGS 1. In the 1981 FES (Ref. 8), the staff discussed the effects of operating SONGS 2 and SONGS 3. The licensee also constructed a 4.6 hectare (11.4 acre) parking lot to the north of SONGS 1 and developed a 49 hectare (120 acre) support and service area, the Mesa Area, to the east of the site on the other side of the San Diego Freeway. Since constructing SONGS 2 and 3, the licensee has extensively modified the site drainage plan. The California Coastal Commission required the construction of a concrete walkway paralleling and adjoining the site sea wall.

With the construction of Units 2 and 3, the licensee added additional overhead transmission circuits to the existing rights-of-way from the facility.

The licensee has also changed specific plant systems and operations at SONGS 1. The FES stated that refueling will take plac. at about 1-year intervals. Current operating procedures call for refueling about every 15 to 18 months.

Two diesel electric generators, each rated at 6,000 kw, supply emergency station auxiliary power. The licensee has removed the 600 kw units described in the 1973 FES and has never installed the 3,800 kw units described in the 1973 FES.

Hourly air pollutant emissions from the exhaust gas from an individual 6,000 kw diesel generator are estimated to be as follows (Ref. 4):

Pollutant Emissions kg/hr/generator b7s/7hr/generator Carbon monoxide

.97 2.13 Hydrocarbons

.52 1.15 Nitrogen oxides 12.02 26.50 (as nitrogen dioxide)

Sulfur dioxide 8.74 19.27 Particulates 1.38 3.04

-8 3.3 Plant Water Use The licensee has made a number of changes in plant water use from that described in Figure 3.3 of the 1973 FES. The licensee has discontinued use of the flash evaporators for the desalinization of saltwater to produce freshwater. Therefore, the licensee no longer adds sulfuric acid to the water to maintain proper acidity. The licensee now purchases water locally from the Tri-Cities Municipal Water District. The licensee has discontinued the use of the biodegradable cellulose sealant to prevent leaks in the main condenser. The licensee no longer uses a leach field to dispose of sanitary waste from the facility as described in the 1973 FES. The licensee has abandoned the leach field. At the southern boundary of Unit 1, the licensee has installed two sanitary sewage treatment plants, that each treat 189,265 liters (50,000 gallons) per day. The sanitary sewage treatment facilities serve all three units. The outflow from the treatment facility is pumped to the Unit 1 seawater discharge line where it mixes with the circulating water flow and is discharged to the Pacific Ocean. Sewage generated at the Mesa Area is treated at the Mesa Sewage Treatment Plant. Effluent from the Mesa Sewage Treatment Plant is also piped to the Unit 1 circulating water system.

3.4 Heat Dissipation Systems Since the staff issued the 1973 FES, the licensee conducted studies that indicated that the physical characteristics of the circulating water system have changed. Total travel time of circulating water from the intake port to the discharge port had decreased from 17 to 14.9 minutes. The top of the discharge structure is 3.5 meters (11.5 feet) below mear lower low-water level (MLLW) and the exit velocity from the discharge structure is 0.76 meters per second (2.5 feet per second). The 1973 FES reported the top of the discharge structure at 3.6 meters (12 feet) below MLLW and the exit velocity from this discharge structure at 0.7 meters per second (2.3 feet per second).

In the 1973 FES, the staff described a heat treatment program for controlling the biofouling of the intake and discharge structures and conduit walls. The licensee currently heat treats the intake conduit and intake structure but not the discharge conduit. The licensee intermittently chlorinates the water to control the biofouling in the discharge conduit.

The current National Pollutant Discharge Elimination System (NPDES) permit for SONGS 1 limits the instantaneous maximum total residual chlorine concentration in the circulating water system at the point of discharge to no more than 0.2 ppm. The 1973 FES reported measured concentration of less than 0.1 ppm. Studies (Ref. 10) over a 3-year period have demonstrated that the total residual chlorine concentrations at the condenser inlet were below 1.0 ppm and below 0.1 ppm at the outfall. In the 1973 FES, the staff reported an intermittent chlorination schedule of six 15-minute intervals each 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The current chlorination frequency is two 60-minute intervals each day.

-9 4.0 ENVIRONMENTAL EFFECTS OF SITE PREPARATION AND PLANT AND TRANSMISSION FACILITIES CONSTRUCTION This section was not updated. Discussions and conclusions included in the 1973 FES remain valid.

5.0 ENVIRONMENTAL EFFECTS OF OPERATION OF THE PLANT 5.1 Impacts on Land Use The effects of the station land use are principally the changes in the recreational and scenic qualities of the site and the loss of undisturbed habitat. The 1973 FES considered the effects of SONGS 1. The 1981 FES for Units 2 and 3 considered the effects of SONGS 2 and SONGS 3. Since issuance of the 1981 FES, the licensee has added a 4.6 hectare (11.4 acre) parking area adjacent to the north side of the station, and a 49 hectare (120 acre) area immediately east of the site on the other side of the San Diego Freeway. The recreational qualities of the site since 1973 may have been improved by the construction of the concrete walkway along the sea wall which may enhance the recreational aspects of the beach. The addition of Units 2 and 3 has changed the scenic quality of the original site since the 1973 FES. Both the new parking area and the addition of the Mesa Area to the east provide no recreational benefit and both can be seen from the San Diego Freeway.

To accomodate the additional electricity generated by Units 2 and 3, the licensee installed additional circuits and tower bases along the transmission line rights-of-way but did not enlarge the rights-of-way.

The staff has evaluated the terrestrial effects of SONGS. The staff reviewed the site drainage pattern and found that the licensee is employing best management practices to control soil erosion. Except for one small area just north of Unit 1 along the sea bluffs, the staff found no significant erosion problems at the site. The site drainage pattern included well defined temporary watercourses and settling basins.

Terrestrial habitat under the control of the licensee is not directly affected by plant operations and is adequately protected with minimal disturbe es. The licensee has allowed most areas to remain in a natural state.

The staff found transmission line rights-of-way to be adequately maintained with little or no erosion along tower access roads. The licensee controls vegetation around tower bases by hand cutting and applies herbicide only to control vegetation at switchyards. The licensee has an active raptor protection program for the transmission lines.

100 10 5.2 Impacts on Water Use In the 1973 FES for San Onofre Unit 1, the staff concluded that the thermal discharge and heat treatment of the circulatory water system was not significant. The staff found that sanitary and chemical effluents released from the facility did not adversely affect the environment. The staff provided a detailed discussion of the effects of entrainment. Entrainment occurs both in the normal-flow mode and in the heat-treatment mode.

Entrainment causes mortality of.organisms in the ocean water column that is drawn into and through the facility. These organisms typically include zooplankton, phytoplankton, and the eggs and larvae of fish. The staff determined that the entrainment of phytoplankton and zooplankton was inconsequential. The staff reviewed the effects of entrainment on a number of fish species, including northern anchovy, jack mackerel, kelp bass, opaleye, walleye surfperch, white seaperch, black perch, California sargo, white croaker and the queenfish. In the 1973 FES, the staff stated that to determine the effect of entrainment on most of the these species, it would require a more complete evaluation of the number of specimens that are entrained.

After the staff issued the FES, the U.S. Environmental Protection Agency (EPA) developed regulations and procedures to implement the provisions in the Clean Water Act (CWA) that apply to aquatic and water quality aspects of nuclear steam electric generating stations. The CWA procedures regulate the major features of the NRC-licensed projects that affect the aquatic environment. The NRC Atomic Safety and Licensing Appeal Board decided in the Yellow Creek case (ALAB-515; 8 NRC 702, 1978) that the NRC does not have the authority to include any non-radiological license conditions for the protection of the aquatic environment, because the CWA places full responsibility for such matters with the EPA (or in this case the State of California to which the EPA has delegated this authority). Effluent limitations, water quality monitoring and the determination of best available technology for intake structures are developed by the EPA or in this case the State of California Regional Water Quality Control Board through the NPDES Permit issued for each facility. On June 14, 1975, the Regional Water Quality Control Board of the State of California issued an NPDES Permit and Wactt Discharge Requirements for SONGS 1. This permit has been renewed several times, the most recent of which was on February 8, 1988 (Ref. 12).

The permit describes the facility, describes the various plant discharges, specifies monitoring of the discharges, requires fish entrainment monitoring, specifies biotic monitoring programs in the vicinity of the facility, limits the discharge of materials and heat that could violate the receiving water quality objectives, and specifies reporting requirements.

Under Section 316(a) of the CWA [33 U.S.C. 1326(a)], State-established thermal effluent limitations in the NPDES permit may be modified to a less stringent level if it can be shown that they are sufficient to "ensure the protection and propagation of a balanced, indigenous population of shellfish, fish, and wildlife."

The regulatory agency's decision to allow alternative thermal discharge limitations (a variance) is based on the

utility's Section 316(a) demonstration, which provides projected thermal effects of the power plant discharge. Every 5 years, the Section 316(a)

"variance" is reviewed during the NPDES permit review procedure. If the Section 316(a) variance is not granted, the utility must comply with established limitations on thermal effluents.

Finding 30 of the Waste Discharge Requirements for SONGS 1, contained in the February 8, 1988, NPDES permit (Ref. 12) issued by the California Regional Water Quality Board, San Diego Region, states that the California regional board reviewed the licensee's August 1973 thermal effect study for Unit 1.

By letter of December 11, 1975, to the licensee, the regional board concurred with the conclusions of the final summary report for the thermal effect study. Therefore, the regional board did not require studies on the SONGS 1 thermal discharge in accordance with Section 316(a) of the CWA, since the SONGS 1 discharge is classified as that of an "old" unit under the State thermal plan.

The regional board concluded that the elevated temperature of the discharge from SONGS 1 does not detrimentally affect the beneficial uses and areas of special biological significance of the receiving waters. The NRC staff agrees with the conclusions drawn by the regional board regarding the effects of the thermal discharges.

Section 316(b) of the CWA [33 U.S.C. 1326(b)] requires that "the location, design, construction, and capacity of cooling water intake structures reflect the best technology available for minimizing adverse environmental impact."

Similarly to Section 316(a) determinations, EPA or in this case the State of California Regional Water Quality Control Board makes Section 316(b) determinations based on data supplied by the utility's Section 316(b) demonstration. Typically, Section 316(b) determinations are usually one-time judgements that are not periodically reconsidered.

However, a determination under CWA Section 316(b) is not permanently binding. If circumstances have changed (such as changes in fish populations, the initial determination is deemed inappropriate, or some adjustment in the operation of the intake structure is warranted), a full Section 316(b) demonstration cold again be required.

In January 1983, the licensee submitted a 316(b) demonstration (Ref. 11).

The report addresses entrainment, impingement, and fish populations in the vicinity of the facility. It evaluates the losses attributable to the SONGS 1 intake structure as compared to offshore population densities and distributions. The regional board has not completed its review of the licensee's 316(b) demonstration.

On February 28, 1974, the California Coastal Zone Conservation Commission issued Permit 183-73 (Ref. 13) authorizing the construction of Units 2 and 3 at the San Onofre Nuclear Generating Station. Southern California Edison and San Diego Power and Light had acquired a vested right to continue

12 operation of SONGS 1 which had begun commercial operation in 1968, predating the Coastal Zone Management Act. No permit for SONGS 1 was required or issued. The February 28, 1974, permit required a continuing study of the marine environment offshore from San Onofre. The study was to be conducted in a manner that would result in the broadest possible consideration of the effects of Units 1, 2, and 3 on the entire marine environment in the vicinity of San Onofre. Although the permit was issued for SONGS 2 and 3 and no permit is required for SONGS 1, SONGS 1 is specifically identified in the February 28, 1974, permit. The permit further states the following:

[if at any time the study indicates that] the project does not comply with the regulatory requirements of State and Federal water quality agencies, or that substantial adverse effects on the marine environment are likely to occur, or are occurring through the operation of Units 1, 2, and 3, the applicants shall immediately undertake such modifications to the cooling system as may reasonably be required to reduce such effects or comply with such regulatory requirements...

The studies were designed and conducted under the direction of the MRC (see Section 2.7.2).

The studies assessed the effect of all three units on the marine environment in the vicinity of the station. Although some studies attempted to assess the specific local effect of individual units, most of the studies evaluated the combined effect of all three units on the environment. As a result, assigning specific levels of impact to the individual generating units is difficult. Perhaps the simplest way is to compare the bmount of flow since entrainment has been identified as one of the most significant potential impacts and entrainment is directly related to flow. The flow rate of ocean water through SONGS 1 is 22 cubic meters per second (350,620 gpm), and the flow rate through SONGS 2 and SONGS 3 is 52 cubic meters per second (830,000 gpm) each. The flow through SONGS 1 is 17 percent of the total flow through all three units. Based on the measured flow rates through the facility, the majority of any impact associated with entrainment would be due to the operation of SONGS Units 2 and 3.

In August 1989, the MRC issued its final. )ort (Ref. 7). The report found no substantial adverse effects on plankton, bottom fauna including invertebrates living in or on the soft sediments, certain mysids, bottom dwelling fish, and intertidal sand crabs. Soft benthos, mysids, and bottom-dwelling fish may have increased in abundance in the vicinity of the station, and that increase might be related to station operation. The MRC final report (Ref. 7) included the following statement regarding the adverse environmental effects that were reported:

...they are not the large-scale ecological disasters. In particular, they are not on the scale of effects predicted during the 1973-74

13 public hearings [on the issuance of the Coastal Zone Permit] which were the stimulus for the creation of the Marine Review Committee.

Key testimony at these hearings predicted that SONGS would create a large inshore ecological desert. This has not occurred.

San Onofre Kelp Bed The MRC (Ref. 7) found that there were adverse effects on the giant kelp, fish and benthic macroinvertebrates inhabiting the San Onofre kelp bed. The MRC studies established that the San Onofre kelp bed has recently increased in size and density, although the increase was less than what was observed at other nearby kelp beds. The staff reviewed the MRC studies and the licensee's annual reports (Ref. 5 and 6) and finds that the extent of the kelp beds varies widely according to factors that are not completely understood. If the operation of SONGS 1 affects the size and distribution of giant kelp near the intake and discharge structures, this effect is not pronounced and it is the staff's opinion that it cannot be accurately quantified at this time.

Fishes Inhabiting the Southern California Bight The MRC also calculated the effect on the standing stock of a number of midwater fish populations in the Southern California Bight. According to the MRC report (Ref. 7), the standing stock of certain species has been reduced by 1 to 10 percent. The MRC also reported a reduction in local abundance of some midwater fish populations.

The entrainment of immature members of certain fish species through the facility results in mortality to some of the individuals entrained. The mortality rate can vary from close to zero to 100 percent depending on the species and the physical conditions to which the immature fish, larvae, or eggs are exposed. The MRC assumed conservatively 100 percent mortality of all organisms entrained through the plant.

The mortality of immature fish can reduce the number of new adults recruited into the adult population each year, reducing the size of the adult population over time.

Fish populations cannot easily be measured in open waters. The MRC study relied on projections of impacts. The estimates of population level impacts made by the researchers are extrapolations made using recruitment models supported by some sampling data but not by direct measurement of impacts.

The MRC concluded that station-induced mortality on immature fish can affect the standing stock of some species in the southern California bight, particularly white croaker, Genyonemus lineatus, and queenfish, Seriphus politus, with reduction in adult populations of 6 percent and 13 percent, respectively.

White croaker is fished commercially and the queenfish has little or no commercial value.

14 The NRC staff has reviewed the MRC report and has concluded that these projected reductions depend on assumptions of the recruitment models. These assumptions are not well founded on empirical data and, therefore, could be incorrect. The magnitude of loss predicted is well within the natural variation of the species examined and at a level that would be difficult or impossible to detect by any known sampling program. Continued operation of SONGS 1 would contribute, based on flow, to less than 20 percent of any actual station-related impacts to fish populations. Even if the MRC projections are accurate, the losses to the populations attributable to SONGS 1 could not be detected.

Local Fish Populations Studies were conducted in the vicinity of SONGS on the fishes inhabiting the water column (midwater fish) and the bottom (bottom fish). The MRC found that the relative densities of two midwater species, the queenfish, S. politus, and the white croaker, G. lineatus, were markedly reduced near The station. In shallow water, the~density of the population of queenfish and white croaker declined by about 60 percent within 1 km of SONGS, and by about 35 percent out to 1.5-3 kilometers (0.9 - 1.8 miles) from SONGS. In deep water, the population density of queenfish was reduced by 50-70 percent, out to 1.5-3 kilometers (0.9 - 1.8 miles) from the plant.

The relative population density of bottom fish increased near SONGS.

The total weight of bottom fish increased relative to the control by about 60 percent in shallow water to more than 100 percent in deep water. Local changes in fish populations caused by station operation are to be expected.

Such changes are generally not significant. The availability of similar habitat up and down the coast from the facility reduces the overall importance of a local depletion of these two species.

The MRC recommended (Ref. 14) that the licensee take a number of mitigative or compensatory measures.

The California Coastal Commission has been investigating compensatory measures such as the construction of an artificial reef that increases fish production or the restoration of a wetland. The California Coastal Commission staff is preparing a report for the Commission that will make recommendations as to how the coastal permit issued to the licensee for SONGS 2 and SONGS 3 will be modifie. cased on the results of the MRC studies. The coastal permit will probably require the licensee to take some compensatory activities. Once the California Coastal Commission issues the permit, the San Diego Regional Water Quality Control Board will act on the 316(b) studies submitted by the licensee.

Conclusion Although the NRC staff has reviewed and evaluated the effects on the marine environment, the staff believes that the regulatory oversight of these matters is under the purview of the State of California. The staff's

15 requirement in this action is to balance the environmental costs of continued operation of the facility against the benefits as required by the National Environmental Policy Act of 1970, as amended (NEPA).

The staff has considered the magnitude and probability of the effects that continuing to operate SONGS 1 will have on the environment. To consider these effects, the staff reviewed the studies conducted under the direction of the licensee arid the MRC. The staff finds that the benefits of continued operation of SONGS 1 outweigh any adverse effects to the marine environment.

Even if the effects described by MRC on the marine environment are accurate, which the NRC staff does not believe is the case, the magnitude of these described effects would still not outweigh the benefits of continued operation of SONGS 1 (see Section 10).

5.8 Impacts On Legally Protected Species Aquatic Species The NRC staff has discussed the occasional impingement of a threatened green sea turtle, Chelonia mdas, at SONGS with representatives of the National Marine Fisheries Service (NMFS). The NRC staff will initiate a consultation with NMFS. The staff will also encourage the licensee to consult with NMFS under the provisions of the Marine Mammal Conservation Act of 1972.

No other legally protected aquatic species could be harmed by continued operation of the facility.

Terrestrial Species The staff finds that a number of legally protected terrestrial species can occasionally use the site and transmission rights-of-way. The staff finds no evidence to suggest that continued operation of SONGS 1 will jeopardize the continued existence of any of the species discussed herein. The licensee has developed and implemented a program that ensures that any of these species will not be adversely affected by using the site or the transmission rights-of-way.

Conclusion The nonradiological effects discussed in the 1973 FES were minor. Since 1973, the licensee has changed the site considerably with the construction of Units 2 and 3, the parking lot, and the Mesa Area. These changes have.

affected land use. However, the effects are minor and local.

The licensee's site drainage program effectively controls erosion. The licensee allows unused areas to remain in a natural state. The terrestrial resources along the transmission lines are not adversely affected. The licensee's program to control erosion along the rights-of-way is effective and does not include chemical control of vegetation.

16 The current controversy regarding the effect on the marine environment of operating SONGS is principally associated with SONGS 2 and SONGS 3.

However, the operation of SONGS 1 also affects the marine environment. The California Coastal Commission is evaluating the results of studies conducted on the marine environment since 1975 and will probably impose some requirements for either mitigative or compensatory activities on the licensee. The staff finds that the regulatory oversight of the effects to the marine environment are appropriately the responsibility of the state regulatory agencies. With regard to the NEPA issues, the staff finds that the potential impacts associated with continued operation of SONGS 1 are acceptable.

The staff also finds that, with the possible exception of the green sea turtle, Chelonia mydas, legally protected species inhabiting the general vicinity of the station and the transmission rights-of-way are not being adversely effected by station operation. Although the staff does not believe that SONGS is affecting the green sea turtle population, the staff will institute consultation proceedings with NMFS for this species.

Therefore, we conclude that the nonradiological effects of converting this license to an FTOL are acceptable.

6.0 ENVIRONMENTAL MEASUREMENT AND MONITORING PROGRAM This section was not updated. Discussions arid conclusions included in the 1973 FES remain valid.

7.0 RADIOLOGICAL EFFECTS The evaluation of radiological effects associated with Unit 1 operations was updated by the licensee on four occasions since the FES was issued in October 1973. The submittals containing the updated information are dated June 7, 1976 (Ref. 21), October 7, 1976 (Ref. 22), February 5, 1986 (Ref.

4), and August 6, 1991 (Ref. 17). The submittals address changes to area demographics, effluent related facility changes, and changes to the effluent release pathways. Additionally, the submittals include actual radioactive release data documenting the first 23 years of plant operations and off-site exposure calculations for the years 1985 thru 1990.

The staff reviewed changes to the facility that were made after the FES was issued to determine whether the changes could affect radioactive effluents or exposures to the offsite population. The review of facility changes, in conjunction with a review of actual radioactive releases that occurred during the first 23 years of operation, was used to project expected radiological impacts during the remaining 12-1/2 years of licensed plant operation. The full-term operating license that was requested by the licensee will expire on March 2, 2004.

17 7.1 Changes to the Plant San Onofre Unit 1 has been upgraded significantly since the FES was issued in 1973. Two events initiated the majority of these modifications. The first event was the accident at Three Mile Island (TMI) in 1979 and the subsequent regulatory response in the form of lessons learned and mandated modifications to all nuclear power stations.

The second event was the SEP. The SEP was an evaluation of nine older power stations, including San Onofre Unit 1, to identify potential safety-significant design differences in these older plants when compared to current licensing criteria. In several cases, resolution of differences identified by SEP resulted in significant modifications to the San Onofre plant.

In most cases the plant upgrades that were initiated by TMI and SEP do not affect normal plant effluents, but rather focus on reducing the likelihood of accidents and, in the event of abnormal occurrences, decreasing the radiological consequences to the public. A list of major modifications is included in the San Onofre Unit 1 full-term operating license related safety evaluation report, NUREG-1443 (Ref. 18).

Examples of modifications that were made to decrease the radiological consequences of accidents include the installation of a post-accident sampling system, installation of hydrogen recombiners, additional post-accident shielding, and emergency response facilities.

Apart from the TMI and SEP required changes, facility changes were made on the basis of other evaluations that identified radiological weaknesses in the plant design. The most notable of these occurred 4n 1977 when the licensee completed construction of a concrete shield around the spherical containment vessel.

The shield was designed to protect personnel from radiation emanating from the containment following accidents that result in fission product release into the containment atmosphere.

Several modifications to the normal liquid and gaseous radioactive waste handling and discharge systems and changes to procedures were made to incorporate lessons learned from operating experience. Modifications to the normal liquid and gaseous radioactive waste processing and discharge systems are described by the licensee submittal dated August 6, 1991 (Ref. 17).

A cryogenic gaseous waste absorption system was installed at Unit 1 in 1972.

After operating the system for several years, the licensee decided to discontinue its use. As described in the FES, the system was designed to collect and hold radioactive gaseous isotopes for at least 90 days. After 90 days most of the gaseous isotopes would decay to negligible amounts.

Krypton-85, a long-lived isotope, would typically be the only radioactive gas remaining in the system. The krypton-85 would eventually be discharged to the atmosphere through the plant stack.

According to the licensee, the cryogenic system required continuous, labor intensive maintenance. Its basic function was duplicated by the waste gas

18 decay tanks. The waste gas decay tank system was much easier to maintain and the licensee chose to process waste gas through the decay tanks rather than through the cryogenic system.

The change did not result in any discernible change in plant effluents.

7.2 Summary of Radioactive Effluent and Exposures The staff reviewed the effluent data from the first 23 years of plant operation, as well as offsite doses which were calculated by the licensee for the years 1985-1990. These data were compared to the projected effluents and their associated doses as presented in the FES. The FES predicted the following:

Airborne Noble Gases 4.4(3 )a Ci/yr Airborne 1131 and Particulates 2.4(-2) Ci/yr Adult whole body dose 6.5(-5) mrem/yr H3 (Liquids) 8.0(3) Ci/yr Mixed Fission & Activation Products (Liquids) 1.8(1) Ci/yr Adult dose (organ unknown) 3.0(-1) mrem/yr Volume of Solid Waste Shipped 4.6(1) m3/yr Activity of Solid Waste Shipped 4.1(2) Ci/yr a) 4.4(3) = 4.4 x 103 As a result of this review the staff concluded:

1) the airborne release rate of noble gases was below the levels predicted by the FES for more than 91 percent of the years that records were maintained,

2) the airborne 1131 and particulate release rate was below the levels predicted by the FES for more than 79 percent of the years that records were maintained,

3) the liquid release rate for tritium (H

3) was always below the FES prediction,

4) the liquid release rate of fission and activation products was below the levels predicted by the FES for more than 96 percent of the years that records were maintained.

19 Exposure guidelines for personnel in unrestricted areas were promulgated by 10 CFR Part 50, Appendix I. Appendix I consists of design objectives for nuclear power plant effluents to meet the criterion "as low as is reasonably achievable (ALARA)" as related to personnel exposures. San Onofre 1 adopted the Appendix I criteria in 1985. Records indicate that, since adoption of the criteria, offsite exposures caused by plant effluents never exceeded the Appendix I design objectives.

San Onofre 1 has a Radiological Environmental Monitoring Program (REMP),

which is utilized by the licensee to demonstrate that environmental radioactive material concentrations and radiation levels are consistent with those determined from the effluent radiation monitoring and sampling program. The latter program is used together with dispersions estimates to ensure the plant releases to the environment and radiation doses to the public are maintained within the Appendix I numerical design objectives.

This program is modified in response to changes offsite and is routinely inspected by the NRC. The staff has never identified significant deficiencies with this program.

Since the FES was issued, the licensee became subject to 40 CFR Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operations."

This regulation considers the doses resulting from the operation of those facilities associated with the uranium fuel cycle. Demonstration of compliance with this regulation involves the doses from liquid and airborne effluents and direct radiation doses from all uranium fuel cycle facilities in the general area of the facility being evaluated. In the case of San Onofre 1, the exposure limits included in this regulatimn were never exceeded.

The FES projected volume and activity associated with solid radioactive waste shipped offsite. The annual volume of the radioactive waste was underestimated by the FES.

However, 89 percent of the annual waste shipments contained less radioactivity than projected in the FES.

Solid radioactive waste shipments including demineralizer and filter media are typically made to the low level radioactive waste disposal sites in Richland, Washington, and Beatty, Nevada. These sites will continue to accept radioactive waste from California until 1993. The California low level radioactive waste site is scheduled to open in 1993. The licensee does not expect an interruption in the ability to ship low level waste off site. If an interruption of waste shipments should occur, the staff will reevaluate this issue.

Through 1980, spent fuel shipments were made from Unit 1 to the General Electric reprocessing facility in Morris, Illinois. At the present time spent fuel is stored on site. The three spent fuel pools located on the San Onofre site have sufficient capacity to permit operation of all three reactors through the year 2004.

200 20 Although radioactive effluents from Unit 1 operations have never exceeded regulatory limits, an offsite contamination incident did occur in 1981 (Ref. 19 & 20). The incident resulted in slight contamination of sand on the beach west of the plant. The source of the contamination appeared to be a drain line from the plant. When the contamination was found in 1981, the drain line was no longer in use. The highest concentrations of activity in the beach sand were 25 pCi/g Cs-137, 12 pCi/g Cs-134, and 6.6 pCi/g Co-60.

In response to the sand contamination, the licensee removed 21,600 cubic feet of sand. The contaminated sand was shipped to the low level waste disposal site in Richland, Washington. Following the excavation, radioactive concentrations in the sand were reduced to 5.0 pCi/g Cs-137.

The exposure rate at the bottom of the excavation was 5 micro-R per hour.

After the excavation was refilled with sand, the dose rate on the surface was negligible. The in-place disposal of this material was approved by the NRC in a letter and evaluation dated September 24, 1981. The ultimate disposal of the contaminated sand will be determined in conjunction with the decommissioning of San Onofre 1.

7.3 Radiological Conclusions Modifications made to the plant since the issuance of the 1973 FES were designed to decrease the likelihood of events that could result in undesirable radiological consequences or to reduce radiological consequences if abnormal events did occur. Procedural changes and modifications to systems that process normal plant effluents were made tc incorporate lessons learned from operating experience. Actual plant effluents were typically below the values projected by the 1973 FES. Since 1985, when the regulations were adopted, exposure calculations for personnel in unrestricted areas indicate compliance with the 10 CFR Part 50, Appendix I, design objectives, and the offsite monitoring program confirms that radiodctivity offsite has not caused exposures greater than the Appendix I design objectives. Based on safety-related plant upgrades and the record of compliance with radiological regulatory criteria during the first 23 years of operation, the staff concludes that the radiological environmental

onsequences of plant operations for the duration of the proposed FTOL are acceptable.

8.0 IMPLICATIONS OF THE PROJECT 8.1 The Requirement for Power When the FES was published in 1973, SONGS 1 had been operating for more than 4 years. The staff concluded that SONGS 1 capacity was required.

The staff does not consider the need for power in its continuing and future license reviews for nuclear power plants unless a showing of "special circumstances" is made under Section 2.758 of Title 10 of the Code of

21 Federal Regulations or the Commission otherwise requires such issues to be considered (see the Commission's rulemaking in 47 FR 12940, March 26, 1982).

8.2 Social and Economic Effects In Section 8.2 of the 1973 FES, the staff discussed the effects of the station and its employees on the local public and economic infrastructure.

The staff concluded that, in balance, the social and economic effects of Unit 1 operation are positive.

The conclusions presented in the 1973 FES remain valid. Tax payments have generally kept pace with rising costs of public services. The present number of employees at the station is approximately 2160 with approximately 340 people assigned to SONGS 1.

The 1973 FES reported an operating staff of approximately 60. The additional employees presently assigned to Unit 1, even though a significant increase, have already integrated in to the regional infrastructure, which has experienced accelerated growth since SONGS 1 began to operate.

9.0 ALTERNATIVES TO THE PROJECT The only alternative considered in the 1973 FES was termination of operations at SONGS 1. The licensee reported that existing older fossil-fueled plants, if available, could not be operated at higher capacity factors to replace power lost by terminating operations at SONGS 1.

The staff concluded that terminating operations at SONGS 1 and not providing power was not a practical alternative. The staff also concluded that purchasing replacement power was not a practical alternative. The staff found that conversion of SONGS 1 to a fossil-fueled plant or to a combined-cycle plant at another location was unrealistic.

The staff further concluded that alternatives to the circulating water system, such as adding a fish return system, modifying the discharge pipe, changing plant operating procedures, using various cooling tower operations and cooli-' ponds, were unwarranted.

According to 10 CFR 51.95, a supplement to a final environmental impact statement on the operation of a nuclear power plant need not include discussions of alternative energy sources or alternative sites.

10.0 BENEFIT-COST ANALYSIS In the 1973 FES, the staff identified the following cost benefit conclusions concerning the facility:

(1) From a national perspective, the principal direct benefit of approximately 3,000,000,000 kWhr of electric power each year to

22 meet the power needs of the area far exceeds the expected environmental costs; and (2) From the local community perspective, the employment, income, and property taxes resulting from operation of the facility exceed any expected disruptions to the local community.

In the 1973 FES, the staff considered as significant environmental costs the loss of fish (36,000 lb/year) and the effects of thermal, chemical, sanitary, and radioactive discharges. The staff concluded in the 1973 FES that all the impacts have been judged to be minor or inconsequential.

In a December 1990 document (Ref. 15) submitted to the Public Utilities Commission of the State of California, the average historical capacity factor of SONGS 1 was estimated at about 55 percent. The licensee expects to achieve an average capacity factor of 70 percent for the period of 1993 to 2004. The lower availability figure is principally due to required modifications to the facility rather than to forced outages or the need for repairs. The licensee predicted that the principal direct benefit will be an average of 2,100,000,000 kWhr of electric power each year and not burning fossil fuels for replacement power.

The indirect benefits to the local community have increased significantly in the areas of the income and employment associated with a larger work force, including the personnel stationed at the Mesa Area, and higher taxes.

The environmental costs of the project have not changed significantly since the staff issued the 1973 FES. The effects on the marine environment of operating the station have been extensively studied. The staff finds the report by the MRC on the effects to the nearby kelp bed and fish populations to be inconclusive. However, even if these effects are as great as estimated, the costs of mitigation or compensation would not be sufficient to upset the benefit-cost balance for the facility and to warrant denying continued operation of the plant and issuance of an FTOL.

11.0 AGENCIES AND PERSONS CONSULTED The Commission's staff has reviewed the licensee's request for an FTOL and has consulted extensively with the licensee, the California Water Quality Control Board, the California Coastal Zone Conservation Commission, the National Marine Fisheries Service, and the California Fish and Game Commissiona.

12.0 BASIS AND CONCLUSION FOR NOT PREPARING AN FES SUPPLEMENT The staff has evaluated the environmental effects of the continued operation of the SONGS 1 and the granting of a FTOL for 40 years from the date of issuance of the construction permit and re-examined the effects initially

23 presented in the 1973 FES. The staff has not identified any significant new environmental effects or any significant changes in those identified previously in the FES that would affect the proposed FTOL for SONGS 1.

Accordingly, the NRC has determined that there are no substantial changes in the proposed actions that are relevant to environmental concerns and there are no significant new circumstances or information relevant to environmental concerns bearing on the proposed action or its effect.

Therefore, the staff has determined that (1) the issuance of an amendment to the FES is not required under NEPA, and (2) the conclusion on page iii, paragraph 7 of the FES, for conversion of the SONGS 1 POL to an FTOL is still valid, except that the technical specifications called for are now included in Appendix I to 10 CFR Part 50 and the NPDES permit.

Principal Contributors: M. Masnik J. Hayes G. Kalman Date:

September 16, 1991

24 APPENDIX Technical reports issued by the Marine Review Committee*

Technical Report Title A

Sand Crabs B

Anomalous Sediments in the San Onofre Kelp Bed C

Entrapment of Juvenile and Adult Fish at SONGS D

Adult-Equivalent loss E

Metals and Radiation F

Kelp Forest Invertebrates G

Mysids H

Mitigation I

Soft Bottom Benthos J

Kelp Bed Fish K

Giant Kelp L

Physical and Chemical Oceanography M

Bight-Wide Effects on Fish: Compensation N

Integration of Local Depressions and Increases in Fish Stocks with Inplant Losses 0

Water Quality Compliance

• From "The Final Report of the Marine Review Committee to the California Coastal Commission," MRC No. 89-02, August 1989.

25 Interim technical reports issued by the Marine Review Committee*

Interim technical report Title 1

Plant Description and Operating History 2

Sampling Design and Analytical Procedures (BACIP) 3 Midwater and Benthic Fish 4

Plankton 5

Fish Larvae and Eggs

26 REFERENCES

1. Southern California Edison Company, "San Onofre Nuclear Generating Station Unit 1, Southern California Edison Company's Environmental Report, Operat ing License Stage, Vol. I and II," August 31, 1972.

2. U.S. Nuclear Regulatory Commission, "Final Environmental Statement Related to Operation of San Onofre Nuclear Generating Station Unit 1," October 1973.

3. Letter from D.M. Crutchfield (NRC) to R. Dietch (SCE), November 5, 1982, "Environmental Review for License Conversion."

4. Letter from M.O. Medford (SCE) to G.E. Lear, February 5, 1986, "Environ mental Review of License Conversion."

5. Southern California Edison Company, "Marine Environmental Analysis and Interpretation, Report on 1989 Data," 90-RD-50, undated.

6. Southern California Edison Company, "Marine Environmental Analysis and Interpretation, Report on 1988 Data," 89-TF-11, undated.

7. Marine Review Committee, "Final Report of the Marine Review Committee to the California Coastal Commission," MRC Document No. 89-02, August 1989.

8. U.S. Nuclear Regulatory Commission, "Final Environmental Statement Related to the Operation of San Onofre Nuclear Generating Station Units 2 and 3,"

NUREG-0490, April 1981.

9. Southern California Edison Company, "San Onofre Nuclear Generating Station Units 2 and 3 Environmental Report - Operating License Phase," Docket No.

50-361/362, 1977.

10. Grove, R.S., "Dispersion of Chlorine at Seven Southern California Coastal Generating Stations," Vol. 4, Book 1 of Proceedings of the Fourth Confer ence on Water Chlorination:

Environmental Imact anT~HeTtEF-cts, Uctobii 18-23, 1981, Pacific Grove, California.

11.

Southern California Edison Company, "Southern California Edison Company San Onofre Nuclear Generating Station Unit 1 316(b) Demonstration,"

January 31, 1983.

12. California Regional Water Quality Control Board, San Diego Region "NPDES No. CA0001228," February 8, 1988.

13. California Coastal Zone Conservation Commission, "Permit No. 183-73,"

February 28, 1974.

27

14. Marine Review Committee "Technical Report to the California Coastal Commission, H. Mitigation," February 1990.

15.

Southern California Edison Company (U338-E) "SONGS 1 Post Cycle 11 Capital Additions," submitted to the Public Utilities Commission of the State of California, December 1990.

16.

U.S. Bureau of Census, "1990 Population Counts for Governmental Units Places."

17.

Letter from R.M. Rosenblum (SEC) to NRC, August 6, 1991, "Docket No. 50-206, Radiological Environmental Impact for FTOL, San Onofre Nuclear Generating Station, Unit 1."

18.

U.S. Nuclear Regulatory Commission, "Safety Evaluation Report Related to the Full-Term Operating License for San Onofre Nuclear Generating Station, Unit 1," NUREG-1443, July 1991.

19.

Letter from K.P. Baskin (SCE) to D.M. Crutchfield (NRC), July 16, 1981, "Disposal of Contaminated Beach Sand, San Onofre Nuclear Generating Station Unit 1."

20. Letter from D.M. Crutchfield (NRC) to R. Dielch (SCE), September 26, 1981, "Slightly Contaminated Beach Sand, San Onofre Unit 1."

21. Letter from K.P. Baskin (SCE) to K.R. Goller (NRC), June 7, 1976, "Supplementary Information Concerning Compliance With 10 CFR Part 50, Appendix I, San Onofre Nuclear Generating Station, Unit No. 1."

22. Letter from K.P. Baskin (SCE) to K.R. Goller (NRC), October 7, 1976, "Supplementary Information Concerning Compliance With 10 CFR Part 50, Appendix I, San Onofre Nuclear Generating Station, Unit No. 1."