ML20233A734

LTR-20-0313 David Victor, San Onofre Nuclear Generating Station (SONGS) Community Engagement Panel, Chair, Et Al., Letter Independent Spent Fuel Storage Installation Security at SONGS and Recent SONGS Community Engagement Panel Meeting on O

ML20233A734
Person / Time
Site:	San Onofre
Issue date:	08/18/2020
From:	Victor D San Onofre Nuclear Generating Station Community Engagement Panel
To:	Kristine Svinicki, Scott(Ois) Morris NRC/Chairman, NRC Region 4
Shared Package
ML20233A735	List: ML20233A734 ML20259A147
References
LTR-20-0313
Download: ML20233A734 (2)

Text

CHAIRMAN Resource From: David G. Victor <david.victor@ucsd.edu>

Sent: Tuesday, August 18, 2020 2:26 PM To: Morris, Scott; CHAIRMAN Resource Cc: Dan Stetson; Martha McNicholas; Manuel Camargo

Subject:

[External_Sender] ISFSI security at SONGS; recent SONGS CEP meeting on "outlier events" chairman@nrc.gov Scott.Morris@nrc.gov 18 August 2020 BY EMAIL

Dear Chairman Svinicki and Regional Administrator Morris,

As you know, the communities surrounding the San Onofre Generating Station (SONGS) are highly active and focused on the ongoing stewardship of the plant. That stewardship hinges on many different factors, including various rulemakings and actions by your Commission.

We are the leadership of the SONGS Community Engagement Panel, a volunteer organization established by the licensee to help ensure a more open twoway line of communication between the communities affected by the closure of SONGS and the operator of the plant and its contractors. Today we write on two fronts.

First, there remains substantial and growing attention to the security, monitoring and management of the ISFSIonly license. Some of these issues concern the need for political action to alter federal law, such as will be needed to make interim storage a practical reality. Some of these concern publicfacing monitoring and robust articulation of defense in depth for the ISFSI. The SONGS site now has a more visible and extensive program in this area than perhaps any site in the country, and all the materials from these meetings and CEP engagement are available at songscommunity.com. In May, we note in particular, that we devoted an entire meeting to outlier events at the ISFSIin particular, terrorismrelated threats. The background materials for that meeting identified a full range of threats, engaged some of the nations leading experts in assessing priorities related to those threats, and assembled a large and growing database of materials related to outlier events at ISFSI facilities.

Second, as part of the May 2020 meeting there was considerable attention to NRCs rulemaking with regard to ISFSI security (rooted in policy paper SECY070148). This arose because the SONGS site already has adopted provisions that go above and beyond the base level security requirements for an ISFSIonly site, and there is keen community interest in how NRC is seeing these issues evolve more generally. (A paper on the above and beyond measures will be circulated to the CEP next week and we are happy to send you a copy.) However, it is our understanding that rulemaking on additional ISFSI security measures was suspended (on staff recommendation) in 2019. Is that still the case? Does the Commission have an updated plan for ISFSI security rulemaking and/or do you believe that any security have been otherwise addressed?

Yours Sincerely, 1

David Victor, SONGS CEP Chair Dan Stetson, SONGS CEP ViceChair Martha McNicholas, SONGS CEP Secretary

David G Victor Center for Global Transformation Professor in Innovation and Public Policy, UCSD School of Global Policy and Strategy Professor of Climate, Atmospheric Sciences and Physical Oceanography (adjunct), Scripps Institution of Oceanography Professor of Mechanical and Aerospace Engineering (by courtesy)

CoDirector, Laboratory on International Law & Regulation CoDirector, UCSD Deep Decarbonization Initiative Senior Fellow, The Brookings Institution UC San Diego, 9500 Gilman Drive #0519 La Jolla, CA 920930519 USA tel: +1 (858) 5343254 facsimile: +1 (858) 5343939 David.victor@ucsd.edu 2