ML081930371

Summary of Meeting with Southern California Edison to Discuss Release for Unrestricted Use of the Off-shore Portion of the Circulating Water System from San Onofre Nuclear Generating Station Unit 1

ML081930371
Person / Time
Site:	San Onofre
Issue date:	07/11/2008
From:	James Shepherd NRC/FSME/DWMEP/DURLD
To:	Mcconnell K NRC/FSME/DWMEP/DURLD/RDB
Shepherd J
Shared Package
ML081930369	List: ML081930371 ML081930374 ML081930543 ML081930580
References
Download: ML081930371 (10)

Text

July 11, 2008 MEMORANDUM TO: Keith I. McConnell, Deputy Director Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs FROM: James Shepherd, Project Engineer /RA/

Reactor Decommissioning Branch Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs

SUBJECT:

MEETING REPORT: PARTIAL SITE RELEASE OF OFF-SHORE PIPING AT SAN ONOFRE UNIT 1 Enclosed is a meeting report from the June 11, 2008 public meeting to discuss the release of off-shore piping from the San Onofre Unit 1 license in accordance with 10 CFR 50.83.

Docket No.: 50-206

Enclosure:

Meeting Summary

July 11, 2008 MEMORANDUM TO: Keith I. McConnell, Deputy Director Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs FROM: James Shepherd, Project Engineer/RA/

Reactor Decommissioning Branch Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs

SUBJECT:

MEETING REPORT: PARTIAL SITE RELEASE OF OFF-SHORE PIPING AT SAN ONOFRE UNIT 1 Enclosed is a meeting report from the June 11, 2008 public meeting to discuss the release of off-shore piping from the San Onofre Unit 1 license in accordance with 10 CFR 50.83.

Docket No.: 50-206

Enclosure:

Meeting Summary DISTRIBUTION:

JWhitten/RIV DOrlando ML081930369 Office DWMEP DWMEP DWMEP Name JShepherd SMichonski APersinko Date 7/11/08 7/11/08 7/11/08 OFFICIAL RECORD COPY

MEETING REPORT Date: June 11, 2008 Time: 6:00 p.m. to 8:00 p.m.

Place: Dana Point Marina Inn 24800 Dana Point Harbor Drive Dana Point, CA 92629

Purpose:

Discuss release for unrestricted use of the off-shore portion of the circulating water system from San Onofre Nuclear Generating Station Unit 1 (SONGS)

Attendees: See Attachment A.

Background:

In December, 2007, Southern California Edison (SCE), licensee for (SONGS) submitted a license amendment application to release part of its site for unrestricted use in accordance with 10 CFR 50.83. Section 50.83(f) requires that U.S. Nuclear Regulatory (NRC) conduct a public meeting as part of its processing of such an application.

Discussion:

Staff from NRC presented an overview of the project management function, including technical review of the licensees application, and inspection function.

SCE presented its plans for releasing the off-shore piping, and an overview of its submittal to the NRC.

Members of the public asked a few questions about potential future uses of the area, including the pipes, after the NRC released it from the license. At this time, there do not appear to be any viable alternate uses of the pipes, and the release will not affect the existing limits on access to the area.

The Alliance for Nuclear Responsibility did not attend the meeting, but submitted written questions on the project. Most of the questions related to interactions between the State of California and SCE (see Attachments 5 and 6). One question was on how background measurements were established. NRC will address this question in its technical review of the application, and the results reported in the Safety Evaluation Report.

Attachments:

1. Meeting Attendees

2. Presentation Slides - James Shepherd, NRC

3. Presentation Slides - Emilio Garcia, NRC

4. Presentation Slides - James Reilly, SONGS

5. Questions from Alliance for Nuclear Responsibility

6. SCE responses to Alliance for Nuclear Responsibility Questions

ATTACHMENT 1 List of Attendees ML081680548

ATTACHMENT 2 Presentation Slides, by James Shepherd, NRC ML081930374

ATTACHEMENT 3 Presentation Slides, by Emilio Garcia, NRC ML081930543

ATTACHMENT 4 Presentation Slides, by James Reilly, SONGS ML081930580

Attachment 5 Questions from Alliance for Nuclear Responsibility

PO 1328 San Luis Obispo, CA 93406 (858) 337 2703 ALLIANCE FOR NUCLEAR RESPONSIBILITY COMMENTS AND QUESTIONS RELATING TO SCES REQUEST FOR PARTIAL SITE RELEASE FOR ITS SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1 Re: Docket No. 50-206 Amendment Application No. 222 to Facility License DPR-13 The Alliance for Nuclear Responsibility provides the following comments and questions for review and consideration by the Nuclear Regulatory Commission.

1. It appears that the "offshore portion of the water circulating system" is to be "abandoned in place"; and it is not clear if SCE needs a Coastal Commission, Fish and Game, Ocean Protection Council or any other state agency permit for this abandonment? If so have these permits been approved?

2. What policies, regulations, procedures did the State Dept of Health or other state agencies arrive at their conclusion that the SCEs abandonment of the offshore portion of the water circulating system would cause no harm? .

3. What level of radiation remains for all portions of SONGS Unit 1 water circulating system and/or other components proposed to be abandoned in place?.

4. What is the involvement of the State Lands Commission - the area is to be returned to their jurisdiction. Is their approval required for SCEs permit to abandon Unit 1 components in place?

5. Will the Coast Guard be consulted? Those pipes under the seabed could be a hazard to navigation. What if some boat tries to anchor and pulls up some of the pipes? Will the area have a prohibition against anchoring?

6. Please explain why the NRC and/or SCE used contaminated concrete from the reactor site as their "background"? This sets a pretty high cleanup level, and allows radioactive components to be "abandoned in place" as offshore structures with no further monitoring or health restrictions.

Please provide responses to the above questions and comments before any permit is granted.

Sincerely,

Rochelle Becker, Executive Director Alliance for Nuclear Responsibility www.a4nr.org rochelle@a4nr.org (858) 337 2703

ATTACHMENT 6 SCE responses to Alliance for Nuclear Responsibility Questions

Information for questions by the Alliance for Nuclear Responsibility regarding Amendment Application No. 222 to Facility License DPR-13 San Onofre Unit 1

1. It appears that the "offshore portion of the water circulating system" is to be "abandoned in place"; and it is not clear if SCE needs a Coastal Commission, Fish and Game, Ocean Protection Council or any other state agency permit for this abandonment?

If so have these permits been approved?

SCE holds an easement lease from the California State Lands Commission for the lands that are the subject of the amendment application. The State Lands Commission amended the easement lease in 2005 to specify the conditions necessary to terminate the easement lease. In accordance with the amended lease, the portions of the system below the seabed will be abandoned in place.

The California Department of Fish and Game, the U.S. Fish and Wildlife Service, and the U.S.

National Marine Fisheries Service reviewed the State Lands Commissions Environmental Impact Report. The State Lands Commission addressed their comments prior to issuing the amended easement lease.

If the NRC approves the amendment request, SCE will seek permits from the state and federal agencies listed below, and other permits as required, to complete the specified work.

• California Coastal Commission Coastal Development Permit

• U.S. Coast Guard anchoring permit

• U.S. Army Corps of Engineers

• Regional Water Quality Control Board, San Diego Region

• U.S. Fish and Wildlife Service

• National Oceanic, and Atmospheric Administration

2. What policies, regulations, procedures did the State Dept of Health or other state agencies arrive at their conclusion that the SCEs abandonment of the offshore portion of the water circulating system would cause no harm?

The California State Lands Commission performed an Environmental Impact Report under the California Environmental Quality Act to amend the easement lease. This report concludes that the proposed action will cause the least environmental harm. Documents related to this report can be found at http://www.slc.ca.gov/division_pages/depm/depm_programs_and_reports/songs/songs_deir.ht ml

3. What level of radiation remains for all portions of SONGS Unit 1 water circulating system and/or other components proposed to be abandoned in place?

Surveys were conducted by SCE in the area subject to the partial site release. The license amendment request documents the results of these surveys. SCE states in their application that the residual radioactive material creates a condition that is a small fraction of the acceptance criteria for unrestricted use. SCE concludes that the final configuration of the Unit 1 conduits

ensures protection of public health and the environment.

The US Nuclear Regulatory Commission will validate the calculations and conclusions as part of the review of the license amendment request.

4. What is the involvement of the State Lands Commission - the area is to be returned to their jurisdiction. Is their approval required for SCEs permit to abandon Unit 1 components in place?

The State Lands Commission has stipulated the conditions and physical work that is required for termination of the easement lease. SCE will submit a written notice certifying completion of the partial removal and abandonment of the conduits and request the termination of the easement lease. The lease will be terminated pursuant to a future Lease termination Agreement between the State Lands Commission and SCE.

5. Will the Coast Guard be consulted? Those pipes under the seabed could be a hazard to navigation. What if some boat tries to anchor and pulls up some of the pipes? Will the area have a prohibition against anchoring?

SCEs proposal is to remove the structures above the seabed thus eliminating the hazard to navigation.

As described in the State Lands Commissions Environmental Impact Report, the final condition of the SONGS Unit 1 offshore cooling water conduits does not present a hazard for navigation.

SCE will notify the US Coast Guard of project activities so that the details may be included on Local Notice to Mariners.

6. Please explain why the NRC and/or SCE used contaminated concrete from the reactor site as their "background"? This sets a pretty high cleanup level, and allows radioactive components to be "abandoned in place" as offshore structures with no further monitoring or health restrictions.

SCE reports that they did not use concrete contaminated with licensed radioactive material as their background when performing surveys for this license amendment.

The United States Nuclear Regulatory Commission will not approve the requested amendment until it is satisfied that the proposed condition meets all regulatory standards, including the treatment of background in calculations to demonstrate compliance with the acceptance criteria.

For your further information, the California State Lands Commission is the agency that manages various California resources, including the tidal and submerged lands adjacent to the entire coast and offshore islands of the State from the mean high tide line to three nautical miles offshore. As such, SCE holds an easement lease from the State Lands Commission for a right of way for the submerged lands that are occupied by the SONGS Unit 1 offshore cooling water conduits.