ML20113E933

SONGS CEP-SCE Joint Response to NEIMA 108 Questionnaire

ML20113E933
Person / Time
Site:	San Onofre
Issue date:	04/22/2020
From:	Office of Nuclear Material Safety and Safeguards
To:	Bauder D, Kern J, Stetson D, Victor D Southern California Edison Co
M DOELL
References
Download: ML20113E933 (7)

Text

NUCLEAR ENERGY INNOVATION AND MODERNIZATION ACT LOCAL COMMUNITY ADVISORY BOARD QUESTIONNAIRE BACKGROUND:

As described in Section 108 of S.512, the Nuclear Energy Innovation and Modernization Act, issued on January 14, 2019, the U.S. Nuclear Regulatory Commission (NRC) is required to prepare a report to the Congress identifying best practices with respect to the establishment and operation of local community advisory boards, including lessons learned from any such board. The boards are intended to foster communication and information exchange between licensees planning for, and involved in, decommissioning activities and members of the community that decommissioning activities may affect.

In an effort to compile this information, the NRC is soliciting your input.

QUESTIONNAIRE: 1 Names/Organizations:

David Victor, Dan Stetson, & Jerry Kern - Leadership of the SONGS Community Engagement Panel (CEP)

Doug Bauder - Vice President and Chief Nuclear Officer, San Onofre Nuclear Generating Station Business email addresses:

david.victor@ucsd.edu dan.stetson@nicholasendowment.org kernjm@hotmail.com doug.bauder@sce.com Is this feedback associated with a particular site? If so, which site?

San Onofre Nuclear Generating Station (SONGS)

Questions applicable to sites where a local community advisory board (CAB) has been established.

Please respond to the questions as applicable.

1) Why was the local CAB established?

SCE and the coowners of the San Onofre Nuclear Generating Station (SONGS) opted to form the CEP after retiring SONGS because such community advisory boards were viewed as an industry best practice and because SCE had a desire to manage decommissioning in an inclusive, forwardthinking, and responsible manner. SCE and the coowners established core principles of safety, stewardship, and engagement to inform their approach to decommissioning and the CEP is consistent with those principles.

2) How and when was the local CAB established?

The CEP was established by SCE and the coowners of SONGS in 2014. SCE benchmarked community advisory boards for other decommissioning/decommissioned nuclear plants across the U.S. and then drafted a charter for the SONGS CEP. The charteravailable hereestablished the purpose,

organization, membership, and meeting structure for the CEP. Initial membersall volunteerswere selected in early 2014 and the inaugural meeting of the CEP was held on March 25, 2014.

Is there a charter for the CAB?

Yes, SCE created a charter for the SONGS CEP in early 2014 and that charter is available here.

3) What is the historical and current frequency of the CAB meetings?

Consistent with the CEP charter, CEP Regular Meetings are held once per quarter. During ramp up in the first year of its formation, the CEP held four regular meetings plus three workshops. From 2015 to present, the CEP has held meetings on a quarterly basis (four times per year).

4) What is the historical and current composition of the local CAB?

The CEP membership was composed to reflect a range of stakeholders in the local communities including local elected officials who are elected by their constituents and pledge to represent the best interests of those constituents. Per the CEP charter, four to six members are to be elected officials from local communities including, as a minimum, cities and counties within what was previously the SONGS 10mile Emergency Planning Zone. This includes the Cities of San Clemente, Dana Point, and San Juan Capistrano. The City of Oceanside is represented as well as the nearest city south of San Onofre. The Counties of San Diego and Orange also are represented on the CEP. At the outset, these stakeholder groups included:

Business Commercial nuclear professionals Environmental nongovernmental organizations Landowner for the SONGS site Local emergency management Local school district Neighboring/nearby cities and counties (local elected officials)

Neighboring state parks Organized labor In 2018, the CEPs composition was expanded to include representation from the local Native American community based on feedback from representatives of the Native American communities. Over time, the CEP has consistently included 18 members, all of whom serve as volunteers.

The CEP charter also calls for three of the CEP members to serve as officers. These include a Chairperson, a Vice Chairperson, and a Secretary.

5) What is the selection process for board members? Has this changed over the lifetime of the CAB?

In, general, CEP members are selected by the SONGS coowners. The coowners strive to select CEP members who are highly engaged and wellinformed leaders in the community and who have the network and credibility to serve as resources to their communities regarding SONGS decommissioning.

The cities and counties represented on the CEP were selected by the SONGS coowners. The cities that are represented on the CEP appoint the representative to the CEP which typically is a member of the city council. The counties that are represented on the CEP are broken up into geographic districts and the CEP member is the county supervisor who represents the district that includes San Onofre (as is the case for County of San Diego) or the district that is nearest the site (as is the case for the County of Orange).

Consistent with the charter, the inaugural Chairperson and Vice Chairperson were appointed by the SONGS Coowners. Subsequent Chairpersons and Vice Chairpersons are selected by the SONGS Co owners with the advice of the CEP. The Secretary is appointed by the Chairperson and serve a twoyear renewable term at the discretion of the Chairperson. In practice, one of the three officers have been an elected official given the value of experience facilitating public meetings.

6) What are the terms of board members?

The CEP charter calls for the inaugural Chairperson and Vice Chairperson to each serve a twoyear renewable term. Each member of the CEP serves a twoyear renewable term (following the initial staggering of terms). The inaugural panel had staggered terms assigned by the SONGS Coowners.

Membership on the panel is renewable at the discretion of the SONGS Coowners.

7) Are there any specific rules or protocols followed by the CAB (e.g., Roberts Rules of Order)?

There are protocols in the charter that govern CEP meetings. These requirements are:

Quarterly meetings Open to the public Strive to have at least half the CEP members present at meetings Publicly noticed at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in advance of a scheduled meeting A public comment period with approximately three minutes per comment, with the period not to exceed one hour Coowners will endeavor in good faith to provide to the members the meeting agenda, the previous meetings minutes, and any pertinent information requiring review prior to the upcoming meeting at least five calendar days before a scheduled meeting

8) Are there any specific logistics required to support the boards meetings and other routine activities? For example, are meetings transcribed, or close captioned, and/or is there audio/visual support for presentations at meetings?

Yes, logistics required for CEP meetings include:

Audio/visual support for presentations Livestreaming via www.SONGScommunity.com Transcriptions are posted to www.SONGScommunity.com Summary meeting minutes are captured and posted to www.SONGScommunity.com Microphone and lectern for public comment

9) Who sponsors (funds) the CAB expenses? What kinds of activities are included in the CAB budget (e.g., transcription service, audio/visual support, meeting venues, meals and per diem for CAB members)?

The SONGS coowners including SCE sponsor CEP meetings. Expenses include:

Rentals including the meeting venue, as well as tables and chairs (if needed)

Audio/visual support (staff and equipment)

Photography Light dinner for CEP members and SCE support staff Reimbursement of expenses (travel and lodging) for CEP members (CEP members are not compensated for their time)

Stipends for guest speakers (as needed for some guest speakers)

Travel and accommodations for guest speakers (as needed)

10) What topics have been (or could be) brought before a local CAB?

Topics that have been brought before the SONGS CEP include:

NRC regulatory filings (such as the PostShutdown Decommissioning Activities Report)

NRC inspections Spent nuclear fuel Radiation monitoring Storage and disposal of spent nuclear fuel o Dry cask storage defenseindepth o Consolidated interim storage o Geologic disposal o Aging Management Programs for dry cask storage o Transferring spent nuclear fuel from pools to onsite dry cask storage o Development of the SONGS strategic plan to relocate spent fuel off the site Spent fuel transportation o Development of the SONGS conceptual transportation plan Emergency planning Security Economic impact of SONGS decommissioning Effluents/discharges Marine mitigation Environmental impact/California Environmental Quality Act Seismic structures/hazards and the seismic design of the structures at SONGS Decontamination & dismantlement

11) How is the boards input used to inform the decisionmaking processes of stakeholders for various decommissioning activities?

Through community engagement and dialogue at CEP meetings, the CEP has helped to inform SCEs decisionmaking process on a handful of key issues.

Due to public interest in safe dry cask storage, when SCE expanded its onsite independent spent fuel storage installation (ISFSI) in 2015, the utility incorporated new innovations in the fabrication process to make its dry storage canisters more resistant to corrosion. These innovations included overrolling the

shells, a twopass weld technique to minimize the heataffected zone, and laser peening of the shell welds to reduce residual stresses.

More recently, due to public interest in radiation data from the SONGS ISFSI, SCE made a commitment to install a system to monitor the ISFSI, stream realtime data to independent agencies, and make monthly reports available to the public via www.SONGScommunity.com. This commitment subsequently was codified in a lease from the California State Lands Commission for the conduits (pipes) that extend offshore beneath the sea floor.

12) What interactions does the local CAB have with the NRC and other Federal regulatory bodies (to support the board members overall understanding of the decommissioning process and promote dialogue between the affected stakeholders and the licensee involved in decommissioning activities)?

Various representatives of the NRC have been invited to and participated in CEP meetings one or more times per year during the six years that the CEP has been in existence. Topics addressed by the NRC at CEP meetings have included:

NRC regulatory filings Emergency planning Security Decommissioning Inspections In addition, the Department of Energy participated in a CEP meeting to address consolidated interim storage. The Department of the Navy is engaged in the CEP via a representative who is appointed to the CEP by Marine Corps Base Camp Pendleton.

13) How does the local CAB offer opportunities for public engagement throughout all phases of the decommissioning process?

After SONGS entered into an unplanned retirement in mid2013, the CEP was formed in early 2014 and held its first meeting in 1Q 2014. The communities in the vicinity of San Onofre have been engaged from the early decommissioning planning phase to present. Public engagement continues through the current campaign to transfer spent nuclear fuel from pools to dry cask storage and the state environmental permitting process. After the required permits are in place, the community will continue to be engaged during decontamination & dismantlement. Throughout, theses phases, the CEP has provided opportunities for public engagement with respect to efforts to relocate SONGS spent fuel to a licensed offsite facility.

14) In general, what are the advantages of having a local CAB?

In our collective judgment, the advantages of a local CAB are:

1. Provides conduit for the utility to learn about the concerns of the community

2. Provides conduit for the community to learn about the impact of the decommissioning process and to hear from subject matter experts

3. Provides for independent expert witnesses and other experts to inform the community on issues

4. Provides point of contact for local communities to discuss issues with regulators and other policy makers

5. Provides for the community to hear from the contractors and to understand their work

6. May positively influence aspects of the decommissioning such as canister peening and radiation monitoring

7. Engages elected officials from affected communities to provide representation and facilitate communication with their constituents

8. Can be a vehicle for establishing trust among the utility and local communities if:

a. Engagement results in conveying information that the community will use

b. Utility demonstrates that they are competent

c. Utility demonstrates they are making decisions with the best interests of local communities in mind

d. Utility demonstrates transparency in its actions and engages in an open dialogue

9. May be a way to engage and energize the community to lobby legislators for action with respect to relocating SONGS spent fuel to a licensed offsite facility

10. If sponsored by a utility, the utility will assist with resources, coordination and insights

11. Flexible control over agenda allows Panel to be responsive

12. Can demonstrate that good people are willing to volunteer and do hard work

15) In general, what are the disadvantages of having a local CAB?

In our collective judgment, the disadvantages of having a local CAB are:

1. If utility forms a CAB and appoints members to the CAB, the CAB may be perceived as a mouthpiece for the utility

2. Many stakeholders, including some regulators and commercial entities, may be wary of semi structured public forums and visibility

3. Potential legal exposure for CAB members

4. Time consuming and expensive

5. Meetings seem to mostly attract dissatisfied activists

6. Turnover with elected officials and the need for ongoing orientation of new CAB members

7. Potential for elected officials to grandstand

16) Please share any best practices or other lessons learned related to having a local CAB.

In our collective judgment, best practices and lessons learned relating to having a local CAB are:

1. Promise, deliver, repeat

a. Open dialogue with the utility/decommissioning agent

b. Transparency and honesty by all

c. Overcommunication with local communities during times of change

2. Addressing the importance of societal considerations - as well of the technical ones

3. Motivated and engaged CAB with members including:

a. Elected officials - representatives of community; adept at public engagement

b. School district

c. Organized labor

d. Business

e. Environmental nongovernmental organizations

f. Native American

g. Emergency management

4. Work to regularly solicit input from members of the CAB

5. Building agendas that address local communities concerns and interests

6. Meetings and workshops with the right experts backed by facts and research

7. Ensure that the CAB has members who can obtain and analyze technical information, including people connected to industry and government that can tap available pertinent information

8. Ensure there are trusted and reliable channels to key regulators (e.g., NRC, state agencies)

9. Ensure that the costs incurred in support of the CAB are treated as prudent expenses for purposes of decommissioning trust fund expenditures

10. Clarify legal backstops at the outset

11. Robust website, regularly updated, addressing questions from the community

12. Tours of the facility for the general public

13. Regular updates with timelines

14. Presentations by contractors with opportunities for questions from the public

15. Regular updates from the NRC, and other federal and state agencies on process, safety and other issues

16. Clear presentations on why decisions are made with the best interest of the public in mind

17. Adequate budget that allows for all of the above, other meetings and travel to relevant manufacturing facilities

18. Addressing environmental concerns

19. Listening, respecting, and then responding can build trust and even advocacy, particularly in the local community

20. Early communication when things do not go as planned and the corrective actions undertaken

21. Be prepared for fake news and disinformation from third parties Questions applicable to sites where a local community advisory board (CAB) has not been established.

Please respond to the questions as applicable.

1) Has the licensee or State ever considered the establishment of a local CAB? When was it considered?

2) What are the reasons for not establishing a local CAB?

3) How does the licensee or State provide opportunities for public engagement throughout all phases of the decommissioning process?

4) In general, what are the advantages of not having a local CAB?

5) In general, what are the disadvantages of having a local CAB?