ML22348A053

NRC to National Marine Fisheries Service (Nmfs), Request to Resume Endangered Species Act Consultation for Decommissioning of San Onofre Nuclear Generating Station, Units 2 and 3

ML22348A053
Person / Time
Site:	San Onofre
Issue date:	11/30/2022
From:	Arlene B Office of Nuclear Material Safety and Safeguards
To:	Lawson D, Mori C US Dept of Commerce, National Marine Fisheries Service
References
Download: ML22348A053 (1)

Text

From: Briana Arlene To: Dan Lawson (Dan.Lawson@noaa.gov); Chiharu Mori - NMFS West Coast Region (chiharu.mori@noaa.gov)

Cc: Amy Snyder; ALBERT BATES; MARK MORGAN; ronald.pontes@sce.com; Brian.Metz@sce.com; Heather.Neely@sce.com; angela.clark1@aecom.com; steven.mannon@aecom.com; bwcouture@energysolutions.com; clytle-bonine@chambersgroupinc.com; Ted Smith

Subject:

Request to Resume Endangered Species Act Section 7 Consultation for Decommissioning of San Onofre Nuclear Generating Station, Units 2 and 3 Date: Wednesday, November 30, 2022 9:19:00 AM

Good morning Dan and Chi,

I am emailing you to request that we resume the Endangered Species Act (ESA) consultation related to the decommissioning of San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS) in San Clemente, California.

During a January 6, 2022, teleconference, the U.S. Nuclear Regulatory Commission (NRC) and National Marine Fisheries Service (NMFS) determined that it was appropriate to pause the consultation until Southern California Edison (SCE), the SONGS licensee, completed dewatering and demucking of the SONGS forebay. We discussed that it was possible that during this effort, workers could discover dead sea turtles that were entrained during the operational period and whose bodies have since remained in the forebay or in other intake system components due to the lack of flow through the cooling water intake system following plant shutdown. Such discoveries would be important information to inform the consultation.

On July 21, 2022, we held another teleconference to discuss the progress of the dewatering/demucking work. At that time, the project was ongoing, and we determined that it was appropriate to continue the pause on the consultation.

On November 10, 2022, we held a third teleconference. SCE informed the NRC and NMFS that it had completed the dewatering/demucking effort and that no sea turtles remains had been discovered. By email dated November 15, 2022, SCE summarized (1) the results of the dewatering/demucking effort, (2)plans for possibly removing the large organism excluder device (LOED), and (3) confirmed that there are no significant changes to decommissioning plans that would affect the NRCs analysis in the biological assessment submitted with the original consultation requested dated September 30, 2021. A copy of SCEs email is below.

Based on this information, the NRC requests that NMFS continue its review of the NRCs original consultation request dated September 30, 2021, as supplemented on December 6, 2021.

Please let me know if you have any questions about this email or if you need any additional information to support your review.

Briana Briana S. Arlene Conservation Biologist & ESA Consultation Coordinator Environmental Center of Expertise Office of Materials Safety and Safeguards U.S. Nuclear Regulatory Commission

briana.arlene@nrc.gov (301) 415-1042

From: Mark E Morgan < Mark.Morgan@sce.com>

Sent: Tuesday, November 15, 2022 4:26:15 PM To: Amy Snyder < Amy.Snyder@nrc.gov>

Cc: Mark E Morgan <Mark.Morgan@sce.com>; Albert Bates <AL.BATES@sce.com>

Subject:

[External_Sender] Summary of Nov. 10 phone call on Biological Opinion

Amy,

As discussed, I wanted to recap the phone call we had with the NRC Biologist and NMFS on November 10 regarding status and plans for the SONGS intake structure in support of changes to the Biological Opinion for SONGS.

During the phone call, we discussed that SCE and its contractors have dewatered the Units 2 and 3 intakes. The Unit 3 intake has been de-mucked and the Unit 2 intake has been de-mucked to the point where it can be inspected to determine if any endangered species had been trapped in the intake structure since Units 2 and 3 stopped operating. No evidence of turtle or marine mammal carcasses was observed.

We also discussed a potential change to the design of the system.

SCE is considering requesting a waiver from the local Regional Water Quality Control Board and/or the State Water Resources Control Board of the requirement to have a Large Organism Exclusion Device (LOED) on the intake openings. SCE believes that an LOED is not necessary to prevent large organisms (endangered or otherwise) from becoming trapped in the intake piping due to the low flow velocity. If SCEs request is approved, SCE will stop maintaining the LOED.

There are no other significant changes in SCEs decommissioning plans that would affect the analysis by NRC biologist or NMFS in support of revising the Biological Opinion.

Please let me know if you need any additional information regarding this.

Thanks, Mark Morgan SONGS Regulatory Affairs