ML21075A283

Summary of Pre-Submittal Teleconference with Soutern California Edison on Request for Proposed Exemption to 10 CFR 72.106(B) (L-2021-LRM-0027)

ML21075A283
Person / Time
Site:	San Onofre
Issue date:	03/17/2021
From:	Amy Snyder Reactor Decommissioning Branch
To:	Southern California Edison Co
Snyder A
References
EPID L-2021-LRM-0027
Download: ML21075A283 (6)

Text

March 17, 2021 LICENSEE: Southern California Edison FACILITY: San Onofre Nuclear Generating Station

SUMMARY

OF FEBRUARY 23, 2021, PRE-SUBMITTAL TELECONFERENCE WITH SOUTHERN CALIFORNIA EDISON ON REQUEST FOR PROPOSED EXEMPTION TO 10 CFR 72.106(b) (L-2021-LRM-0027)

The U.S. Nuclear Regulatory Commission (NRC) conducted a pre-submittal meeting with representatives of Southern California Edison (SCE) on February 23, 2021. The purpose of the teleconference was to discuss SCEs proposed exemption request to decrease the controlled area boundary (CAB) of the San Onofre Nuclear Generating Station (SONGS)

Independent Spent Fuel Storage Installation (ISFSI) to less than what is required per Title 10 of the Code of Federal Regulations (10 CFR) 72.106(b).

The meeting announcement, with agenda, is found at Agencywide Documents Access and Management System (ADAMS) Accession No. ML21043A072. The meeting began with opening remarks by the NRC staff, followed by introductions by the SCE attendees. The complete list of attendees is provided in the enclosure; SCEs presentation slides are found at ADAMS Accession No. ML21053A238, and the NRCs staffs presentation slides are found at ADAMS Accession No. ML21053A441.

The NRC staff stated that it would not make any decisions at the meeting, but the NRC staff would listen to licensees proposed plans for preparing a potential request to move the ISFSI CAB. The NRC staff noted it would comment whether the proposed approach appears to be reasonable and appears to follow the NRC process. The NRC staff explained that these types of meetings are optional, but encouraged, because they have been shown to lead to high quality applications regarding completeness and reduction in the number of requests for additional information.

SCE explained that, based on its interactions with California State Lands Commission, a key State agency, and the provisions of its State lease, it is required to reduce or eliminate the SONGS site exclusion area boundary (EAB) consistent to the maximum extent allowed by law. Also, it shared with the NRC that there is public interest in unfettered access to the Beach at SONGS. SCE plans to eliminate the EAB and to retain the Site boundary and ISFSI CAB. However, the ISFSI CAB must be also addressed because it currently extends on the beach and would require NRC approval to move it to the other side of the seawall. If NRC approval is obtained, SCE would then be able to pursue the elimination of the offsite agreements for control of public access to the beach in front of the SONGS facility under emergency conditions.

2 During its presentation, SCE stated it was SCEs understanding that the basis for the ISFSI 100 m CAB is radiological protection. The NRC staff stated that is the NRC staffs understanding, but the NRC staff would verify that during its technical review should SCE apply for the exemption. The NRC staff also stated that it is important to note that this distance requirement is based on direct radiation from applicable design basis accidents and not effluents.

SCE also asked what controls are applicable to NRC regarding controlling the ISFSI CAB?

The NRC staff referred SCE to the 2005 Humboldt Bay safety evaluation report for allowing a publicly accessed trail through the ISFSI CAB. The NRC staff explained that during cask transfer and storage operations, the public trail is controlled using locked gates to keep members of the public out of the ISFSI CAB and described other controls at Humboldt Bay, such as agreements with the Coast Guard, to limit access from the 100 m distance that extended into the bay. However, the NRC staff stated that it is important to note that NRC did not grant an exemption to the 10 CFR 72.106(b) 100 m distance in this instance, but evaluated this request under 10 CFR 72.106(c) (e.g., the controlled area may be traversed by a highway, waterway, or railroad).

The NRC staff asked SCE what regulatory approaches SCE is thinking about regarding potentially shrinking the ISFSI CAB. SCE stated that it would be asking for an exemption if it decides to move forward with an application. The NRC staff then asked whether SCE would ask for any exemptions specific to Certificates of Compliance Technical Specifications. SCE said that it was not going to ask for such exemptions.

The NRC staff asked whether SCE would be performing dose evaluations under 10 CFR 72.104, Criteria for radioactive materials in effluents and direct radiation from an ISFSI or MRS and 10 CR 72.106, Controlled area of an ISFSI or MRS to demonstrate dose limits are met for less than 100 m distance as part of its application. SCE said that it would perform those evaluations through the 10 CFR 72.48, Changes, tests, and experiments process.

The NRC staff noted that based on the SCEs presentation, it appears that there would be no need to modify the SONGS physical security plan. The NRC staff asked how SCE plans to address the change in the EAB with respect to the Environmental Protection Area (EPA)

Protective Action Guides (PAGs). SCE stated that the EAB and ISFSI CAB would be the same boundary and SCE would show that the EPA PAGs would be met at the ISFSI CAB through a 10 CFR 50.54q evaluation. The staff voiced no regulatory process concerns with the proposed SCE strategy.

At this meeting, the NRC staff made no regulatory decisions regarding the merits of the proposed amendment request. The NRC staff inquired that if SCE decides to submit the exemption application, is there an estimated timeframe when the decision would be made.

SCE estimated that the application would be submitted sometime in March 2021, at the earliest. There were no action items as a result of this discussion from either NRC staff or SCE.

After the business portion of the meeting, the governmental representatives and officials and members of the public participating in the meeting were asked if they have any questions for the NRC staff about the regulatory process for the proposed action. Also, the NRC staff noted that if the public had other questions for the NRC staff, please submit them to the NRC public affairs office at OPA.Resource@nrc.gov and the NRC staff would respond. There were no questions.

3 Please direct any inquiries to me at (301) 415-6822 or Amy.Snyder@nrc.gov.

Signed by Snyder, Amy on 03/17/21 Amy M. Snyder, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-206; 50-361; 50-362

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES FEBRUARY 23, 2021 MEETING WITH SOUTHERN CALIFORNIA EDISON SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 Affilation FirstName LastName Email NRC Joseph Anderson joseph.anderson@nrc.gov NRC Leira Cuadrado leira.cuadrado-caraballo@nrc.gov NRC michael norris michael.norris@nrc.gov NRC John McKirgan john.mckirgan@nrc.gov NRC Bruce Watson bruce.watson@nrc.gov NRC Richard Chang richard.chang@nrc.gov NRC Marlayna Doell marlayna.doell@nrc.gov NRC Amy Snyder amy.snyder@nrc.gov NRC Andrew Barto andrew.barto@nrc.gov NRC Jessie Quichocho jessie.quichocho@nrc.gov NRC Stacey Imboden stacey.imboden@nrc.gov NRC Greg Chapman gregory.chapman@nrc.gov SCE Heather Neely heather.neely@sce.com CA Energy Commission Justin Cochran justin.cochran@energy.ca.gov SCE Derek Brice derek.j.brice@sce.com SCE Al Bates al.bates@sce.com NRC Earl Love earl.love@nrc.gov SCE Steven Giannell steven.giannell@sce.com NRC William Maier bill.maier@nrc.gov NRC Azmi Djapari azmi.djapari@nrc.gov NJ State Jerry Humphreys jerry.humphreys@dep.nj.gov NRC Rhex Edwards rhex.edwards@nrc.gov US Senator Dianne Feinstein Shelly Abajian shelly_abajian@feinstein.senate.gov SCE Lucia Sischo lucia.sischo@sce.com NRC Dave McIntyre david.mcintyre@nrc.gov NRC Marlone Davis mxd3@nrc.gov NRC Alison Rivera alison.rivera@nrc.gov NRC Douglas Garner douglas.garner@nrc.gov SCE Mark Morgan mark.morgan@sce.com Legal Ariel Braunstein ariel.braunstein@morganlewis.com CA State Lands Commission Cynthia Herzog cynthia.herzog@slc.ca.gov Enclosure

Affilation FirstName LastName Email SCE Randall Granaas randall.granaas@sce.com SCE Kenneth Wilson kenneth.r.wilson@sce.com NextEra Energy Duane Arnold Mike Davis j.michael.davis@nee.com NRC Matthew Learn matthew.learn@nrc.gov SCE Vince Bilovsky vince.bilovsky@sce.com AECOM Steven Mannon steven.mannon@aecom.com vld@nrc.gov NRC Victor Dricks NRC Stephanie Anderson stephanie.anderson@nrc.gov U.S. House Kyle Krahel kyle.krahel@mail.house.gov SCE Jerry Stephenson jerry.stephenson@sce.com NRC Samantha Lav samantha.lav@nrc.gov NRC Janelle Jessie janelle.jessie@nrc.gov SCE Ross Quam ross.quam@sce.com CA State Lands Commission Cheryl Hudson cheryl.hudson@slc.ca.gov NRC Angel Moreno angel.moreno@nrc.gov SCE Kelli Gallion kelli.gallion@sce.com NRC Jeremy Tapp jeremy.tapp@nrc.gov NJ State Veena Gubbi veena.gubbi@dep.nj.gov UxC, LLC Carlyn Greene carlyn.greene@uxc.com CA State Lands Commission Lucinda Calvo lucinda.calvo@slc.ca.gov Exchange Monitor Publications Benjamin Weiss bweiss@accessintel.com

Memo ML21075A283 OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP/RDB NAME ASnyder AS BWatson BW ASnyder AS DATE Mar 16, 2021 Mar 17, 2021 Mar 17, 2021