ML15258A672

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Notice of Violation of NPDES Permit
ML15258A672
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 09/10/2015
From: Kay J, Morgan M
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15258A672 (8)
v • d • e


Text

EDISON An EDISON INTERNATIONALS M Company September 10, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

Subject:

Docket No. 50-361 and 50)-362 Notice of Violation of NPDES Permit San Onofre Nuclear Generating Station, Unit 2 and Unit 3

References:

1) Letter from Brian Metz, Southern California Edison to David Gibson, California Regional Water Quality Control Board San Diego Region, dated September 25, 2014
2) Letter from Ben Neill, California Regional Water Quality Control Board, San Diego Region, to Brian Metz, Southern California Edison, dated July 10, 2015

Dear Sir or Madam:

Appendix B, Section 3.2, of Operating License Nos. NPF-1 0 and NPF-1 5 for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 respectively, requires violations of the National Pollutant Discharge Elimination System (NPDES) Permit or State certification (pursuant to Section 401 of the Clean Water Act), to be reported to the NRC by submittal of copies of the reports required by the NPDES Permit or certification.

On September 15, 2014, during a review of the NPDES self-monitoring reports, SCE staff discovered that annual and semi-annual samples and required reports that were due in 2014 were not submitted on time to the San Diego Regional Water Quality Control Board. SCE verbally notified the offsite agency of the missed reports; including notification to the NRC of the offsite notification to an outside agency per 10 CFR 50.72(b)(2). A follow-up letter was sent to the California Regional Water Quality Control Board on September 25, 2014 (Reference 1 )

documenting the reports that were missing and the corrective actions that SCE had executed to ensure that the missed reporting noted in the letter would not occur in the future.

A Staff Enforcement Letter from the California Regional Water Quality Control Board to SCE SONGS dated July 10, 2015 (Reference 2) was received documenting the self-identified late reports (Reference 1) as a violation for submitting late reports. No response or additional action is required by SCE.

Additional details can be found in the enclosed referenced letters.

P.O Box 128c o )

San Clemnente, CA 92674-0 128 i/

Document Control Desk Spebr1,21 September 10, 2015 There are no commitments in this letter or the enclosures.

If you have any questions please contact Mr. Mark Morgan at (949) 368-6745.

Sincerely,

Enclosures:

1) Letter from SCE to California Regional Water Quality Control Board, San Diego Region
2) Letter from California Regional Water Quality Control Board, San Diego Region, to SCE cc:

M. L. Dapas, Regional Administrator, NRC Region IV M. G. Vaaler, NRC Project Manager, SONGS Units 2 and 3 R. L. Kellar, NRC Region IV Branch Chief, Repository Spent Fuel Safety Branch S. Hsu, California Department of Public Health, Radiologic Health Branch Letter from Southern California Edison to California Regional Water Quality Control Board, San Diego Region

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September 25, 2014 Mr. David Gibson California Regional Water Quality Control Board San Diego Region 2375 Northside Drive Suite 100 San Diego, California 92108-2700 IC: 13-0086.01

Subject:

Follow-up report for the missed semi-annual (2013 second half; 2014 first halt) and annual report (2013): Order No, R9-2005-0005 (NPDES Permit No. CA0 108073) and Order No. R9-2005-0006 (NPDES Permit No. CAOIO81SI!).

Dear Mr. Gibson:

On September 15, 2014, during a review of the NPDES self-monitoring reports, SOE SONGS environmental staff discovered that the following reports were not submitted and are now past due:

Unit 2 Semi-annual Report, 2013 second half Unit 3 Semi-annual Report, 2013 second half Unit 2 Annual Report, 2013 Unit 3 Annual Report, 2013 Unit 2 Semi-annual Report, 2014 first half Unit 3 Semi-annual Report, 2014 first half The missed samples and associated reports are non-radiological in nature.

The oversight appears to be due to the staff changes and lack of familiarization with programe requirements. SCE is also performing a self-assessment to ensure that any gaps in procedure, reports and/or lack of clarity with respect to roles and responsibilities are promptly addressed.

o Interim corrective actions have been taken including the assig-nment of a SONGS experienced environmental manager to provide oversight and direction for compliance matters, including the NPDES monitoring and reporting requirements.

,* SOE will submit the 2013 Annual Report with the summaries of the monthly and quarterly monitoring data that.had been gathered for the 2013 year in both tabular and graphical format byK:Qdtbber 16, 2Of.No analytical data exists for the semi-annual reports or the annual repdrt.

  • Semi-annual and annual sampling have been completed during the week of September 25, 2014 and the results will be provided to the San Diego RWQCB upon receipt.

SCE made verbal notification to Ben Neill on September 19, 2014.

If you ha~e any. questions please contact m at (949) 68 731 NnaeEnvironmental '

B. C) !3os I2 Son C'icnintc, CA

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cc:

Ben Neill (SDRWQCB)

John Brabec Kelli Gallion Paul Elliott Jr Paul Youngbae Aim 1DB - NPDES 0DM Letter from California Regional Water Quality Control Board, San Diego Region to Southern California Edison

Water Boards EO*,,U'O Q. Sr*OWN JR.

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Place ID 257702:25770]3:Bneill

Subject:

Staff Enforcement Letter, 2013 through 2015 Self-Monitoring Reports (SMRs) for SONGS Unit 2 and 3, Order Nos. R9-2005-0005 and R9-2005-0006, NPDES Permit Nos.

CACI 08073 and 0A0108181 Mr. Metz:

.2013 and March 2015 for the aforementioned facility:

Monthly SMRs - October 2013 through March 2015 Quarterly SMRs - October 2013 through December 2014 Semi-annual SMRs - July 2013 through December 2014 SAnnual SMRs-2013through 2014 The following is a summary of the San Diego Water Board's findings:

1. Violation - Late Report, Attachment 0 Section X!II.5
a. The following reports were submitted past due:

° Monthly, August 2014.

Semi-annual, H2 2013 and HI 2014 Annually, 2013

~HE-NRY ACARBANEL, CHAIR DAVlD GIBSON, EXE(CUTIlV-OFFICER

'237S Northslde Drive, Suite 100, San Diego, CA 92105.2700 I (69 1619 I www.waterboards.oa~govlsandlegb SRecycIed Paper

Mr, Metz Mr.

Mez July 10, 2015 Please take steps; to ensure that the violations noted above do not occur in the future. Pursuant to the California Water Code (CWC), the violations noted are subject to additional enforcement action(s) by the San Diego Water Board including a time schedule order, cease and desist order, cleanup and abatement order, imposition of administrative civil liability, referral to the district attorney for criminal prosecution*, or referral to the attorney general. Administrative civil liability amounts that may be imposed by the San Diego Water Board under authority of CWC Section 13385 include up to $1 0,000 per day, or up to $10 per gallon for each gallon of waste discharged.

In the subject line of any response, please include the reference "Place ID 257702:257703:Bneill". For questions or concerns regarding this letter, please contact Ben Neill at 619-521-3376 or ben.neillc~waterboards. ca.,q ov.

Ben Neill, R.E.

Water Resources Control Engineer Source Control Unit Tech,Staff info & Use Order No.

R9-2005-0005 WDID 9000000087 NPDES No, CA0108073 Reg. Measure ID t3$338 (R9-20.05-0005)

Place ID 257702 Enforcement ID 402000 Violation(s) 992803; 992805;

_________________992,806; 992807 Tech Staff Info & Use Order No, R9-2005-0006 VVDID 9 000000088 NPDES No.

CAOIO08181 Reg. Measure ID 133389 (R9-2005-0006)

Place ID 257703 Enforcement lD 402000 Violation(s) 992804; 992808;

________________992809; 992810 2375 Northalda Crlva,-8uite '100, San Diego, CA 92108-2700 I (6191 616-'1690 I www~waterboardiacaogovlaandlego Recycled lPaper

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