ML20037A150
| ML20037A150 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/19/2020 |
| From: | Bruce Watson Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Oestereicher M US Dept of the Navy |
| R CHANG | |
| Shared Package | |
| ML20037A149 | List: |
| References | |
| Download: ML20037A150 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 19, 2020 Captain Michael P. Oestereicher, CEC, USN Commanding Officer Naval Facilities Engineering Command Southwest 1220 Pacific Highway San Diego, CA 92132-5190
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION PERSPECTIVE REGARDING PROPERTY RELEASE OF THE MESA AREA AT THE SAN ONOFRE NUCLEAR GENERATING STATION
Dear Captain Oestereicher:
On December 19, 2019, Southern California Edison Company (SCE) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) staff to respond to the U.S. Navy regarding the NRCs role with respect to the termination of SCEs leasehold interest in the Mesa area and its return to the control of the Department of the Navy (Navy). The NRC staff understands that the Navy is concerned about minor radiological contamination events that took place in the Mesa area during the 1980s.
Based on a review of information compiled by SCE, the NRC staff previously affirmed in our letter dated December 1, 2015, and continues to affirm in this letter, that SCE appropriately addressed and remediated these events. Our review is discussed in an attachment to this letter. The documents provided by SCE are publicly available in NRCs Agencywide Documents Access and Management System (ADAMS) at accession number ML20034D837.
As discussed in NUREG-1757 Volume 2, Consolidated Decommissioning Guidance, it is long-standing NRC policy that equipment and material must be surveyed with no detectable licensable material above background levels before release from the site, or it must be treated as waste. Section 15.11 of NUREG-1757 states:
Reactor licensees typically follow a policy that was established by Office of Inspection and Enforcement Circular 81-07 and Information Notice 85-92. Under this approach, reactor licensees must survey equipment and material before its release. If the surveys indicate the presence of AEA material above natural background levels, then no release may occur. If the appropriate surveys have not detected licensable material above natural background levels, the solid material in question does not have to be treated as waste under the requirements of Part 20.
In instances where material has inadvertently left the site, the licensee must expeditiously return the contaminated material to the site and ensure the affected area is remediated to safe levels.
M. Oestereicher 2
Based on NRCs staffs review of SCEs December 19, 2019, letter and previous documentation, SCEs actions appear to have been consistent with this policy.
The Mesa area is outside of the NRCs licensed boundary for San Onofre Nuclear Generating Station (SONGS), and therefore, absent any evidence of current radiological contamination linked to licensed activities at SONGS, is not subject to the NRCs regulatory authority. If radiological material originating from SONGS were identified in the MESA area, NRC would have regulatory authority over that material. However, since no SONGS material has been identified after recent surveys, and previously identified material was immediately removed (and the area was surveyed at that time), the Mesa area is not subject to NRC jurisdiction because the dose limits in 10 CFR 20.1402 are not exceeded. In conclusion, based on the information provided by SCE and the NRCs inspection practices at the time, the NRC has no current concerns regarding any residual radioactivity at the Mesa.
The NRC has no knowledge of any other licensed activities being performed in the Mesa area outside of what has been reported in SCEs December 19, 2019 letter.
If you have additional questions or concerns, please contact Mr. Richard Chang, SONGS Project Manager, who can be reached at 301-415-5888.
Sincerely,
/RA/
Bruce A. Watson, CHP, Chief Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-361 and 50-362 License Nos.: NPF-10 and NPF-15
Attachment:
NRC Review of SCE December 19, 2019 Letter cc: SONGS Listserv Commanding General, Marine Corps D. Bixler E. Abkemeier