Self-Assigned Surfrider Foundation Question (1) Who are the entities that have jurisdiction over the storage, transportation, and safety of spent nuclear fuel and nuclear waste? What

are their roles, responsibilities, limits, and funding implications?

Research conducted by Nolan Fargo, Summer Legal Intern, under the guidance of Katie Day, Staff Scientist, Surfrider Foundation, for the SONGS Technical Advisory Committee for the Task Force of Rep.

Mike Levin, CA-49.

A. Introduction There are multiple agencies at the local, state, and federal levels that have jurisdiction over the storage, transportation, and safety of spent nuclear fuel (SNF) and nuclear waste. The lead agency is the federal Nuclear Regulatory Commission (NRC). The NRC is the agency that licenses, regulates, and oversees all aspects of nuclear power generation—including the storage, transportation, and safety of SNF and nuclear waste. However, the NRC works with other federal agencies such as the Federal Emergency Management Agency (FEMA), the U.S. Environmental Protection Agency (EPA), and the U.S. Department of Transportation (DOT) to oversee emergency response, environmental safety, and transportation of nuclear waste, respectively. Under the Nuclear Waste Policy Act of 1982 (NWPA), the NRC is also authorized to work with the U.S. Department of Energy (DOE) to develop a permanent repository for the nation's SNF. The actual disposal of the SNF in a repository is the DOE's responsibility, while NRC is responsible for licensing and overseeing the disposal. Currently, there is no location for the interim storage or permanent disposal of any of the nation's commercially-generated SNF. On the state level, various state land-use agencies, such as the California Coastal Commission (CCC) and the California State Lands Commission (SLC) have jurisdiction over applicable land-use permits and leases for construction, operation, and maintenance of nuclear power plants on state land. On the local level, local governments are largely responsible for emergency response in the event of an accident at a nuclear power plant that causes the release of radioactive material into the surrounding environment. Local governments also play a large role in keeping their constituents informed about events at nearby nuclear power plant facilities. The following is an overview of the various roles, responsibilities, limits, and funding implications of the entities that have jurisdiction over the storage, transportation, and safety of SNF, with specific focus on the San Onofre Nuclear Generating Station (SONGS). B. Local towns/cities/counties The NRC's emergency preparedness regulations require each nuclear power plant operator to submit radiological emergency response plans of state and local governments that are within the 10-mile plume exposure pathway1 Emergency Planning Zones, as well as the plans of state governments within the 50-

1 For emergency planning purposes, the plume exposure pathway includes everything within a ten-mile radius of a

nuclear power plant. Human health and safety risks associated with being within the plume exposure pathway during an emergency include: whole body injury from exposure to gamma radiation; and thyroid, lung, and possibly other organ injury from inhalation of radioactive materials. U.S. NRC, Emergency Planning Zones, https://www.nrc.gov/about-nrc/emerg-preparedness/about-emerg-preparedness/planning-zones.html; FEMA, Tab. 1 to Attachment F Nuclear Power Plant Accident, p. 6-F-1-1, https://www.fema.gov/pdf/plan/6-ch-f-1.pdf.

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mile ingestion pathway2 Emergency Planning Zones.3 Accordingly, local towns, cities, and counties are, in large part, responsible for the safety of their citizens in the event of an emergency situation at a nuclear power plant. This includes various public safety capabilities such as law enforcement, fire and medical, radiological monitoring, multi-agency coordination, and dissemination of public information. To protect the public in the event of an emergency, the towns, cities, and counties develop and maintain emergency planning to provide: (1) guidance to their citizens; and (2) an appropriate response to an emergency situation. The Interjurisdictional Planning Committee (IPC) oversees emergency planning at SONGS.

1. IPC The IPC was formed in 1982 to address the emergency planning requirements within the Emergency Planning Zone for SONGS.4 The Emergency Planning Zone is the area within a 10-mile radius from San Onofre.5 The IPC is composed of representatives from the following entities:

● City of San Clemente; ● City of Dana Point; ● City of San Juan Capistrano; ● Orange County; ● San Diego County; ● Marine Corps Base Camp Pendleton; ● California State Parks; ● Southern California Edison (SCE).6

2 For emergency planning purposes, the ingestion pathway includes everything within approximately fifty miles of

a nuclear power plant. It is called the ingestion pathway because in the event of an emergency human health and safety risks can occur if food and water from within the ingestion pathway is consumed. The health and safety risks include whole body and thyroid injury. U.S. NRC, Emergency Planning Zones, https://www.nrc.gov/about-nrc/emerg-preparedness/about-emerg-preparedness/planning-zones.html; FEMA, Tab. 1 to Attachment F Nuclear Power Plant Accident, p. 6-F-1-1, https://www.fema.gov/pdf/plan/6-ch-f-1.pdf. 3 10 CFR § 50.33(g). To obtain an operating license, the licensee must submit radiological emergency response

plans of state and local governments that are within the plume exposure and ingestion pathways. Id. In the NRC regulations, the onus is on the licensee, not the state or local governments. Id. Under California state law, local governments within the plume exposure pathway are required to develop and maintain radiological emergency response plans. CA Health & Safety Code § 11467. The state Department of Health services is responsible for emergency planning and preparedness within the ingestion pathway. CA Health & Safety Code § 114662. Once a reactor's operating status changes from operating to decommissioning, there is no further off-site emergency planning requirements. 10 CFR § 50.82(a); U.S. NRC, The Decommissioning Process and Emergency Planning, https://www.nrc.gov/docs/ML1623/ML16230A576.pdf. However, in December 2015 the IPC entities agreed to continue off-site radiological emergency planning during the decommissioning process. IPC, MEMORANDUM OF UNDERSTANDING FOR SUPPORT OF RADIOLOGICAL EMERGENCY PLANNING AND RESPONSE, http://www.danapoint.org/Home/ShowDocument?id=16449 (p. 3). 4 SONGS Community, Emergency Planning Partnerships, https://www.songscommunity.com/safety/emergency-

planning-partnerships. 5 Id. 6 Id.

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The IPC's mission is to integrate emergency plans, coordinate decision-making for SONGS-related activities, and educate the public.7 The IPC is a partnership that is recognized at the local, state, and federal levels.8 The IPC meets monthly throughout the SONGS decommissioning process.9 Furthermore, each IPC jurisdiction maintains their own emergency response plan that is specific to an emergency at SONGS.10 However, the IPC entities worked together to develop joint standard operating procedures (SOPs) and policies that all the entities will follow during a response to an emergency event at SONGS.11 For example, San Diego County's Office of Emergency Services provides independent monitoring of SONGS decommissioning, independent radiological dose assessment capabilities, and regular and consistent notification to the public regarding SONGS decommissioning and SNF storage.12

Currently, the power plant operator, SCE, funds 100% of offsite emergency planning, training, equipment maintenance and calibration, and emergency response costs.13 In December 2015, the IPC and SCE signed a memorandum of understanding (MOU) that stated that SCE would provide 100% funding through FY2019-2020.14 The MOU further states that SCE will provide 75% funding in FY 2020-2021, and 50% funding in FY2021-2022.15 Thereafter, the state of California will provide funding for planning and preparedness costs, equipment purchase and calibration, training, and exercises costs.16 C. State government and agencies

1. Governor California is an NRC "Agreement State."17 Agreement States enter into agreements with NRC that give the state the authority to license and inspect byproduct, source, or special nuclear materials used or possessed within the state's borders.18 In 1962 the Governor entered into this agreement with NRC, but

7 Id. 8 Id. 9 Orange County Sheriff's Department, San Onofre Nuclear Generating Station, Interjurisdictional Planning

Committee (IPC), https://www.ocsd.org/divisions/fieldops/emergency_management/san_onofre_nuclear_generating_station. 10 National Radiological Emergency Preparedness Conference PowerPoint:

http://www.nationalrep.org/2016Presentations/Session%2027_Decommissioning%20of%20the%20San%20Onofre%20Nuclear%20Generating%20Station_Kaminske-Amabile-Harriman.pdf. 11 San Diego County Office of Emergency Services, SONGS Facts and Preparedness,

https://www.sandiegocounty.gov/content/sdc/oes/emergency_management/oes_jl_SONGS.html. 12 Id. 13 National Radiological Emergency Preparedness Conference PowerPoint:

http://www.nationalrep.org/2016Presentations/Session%2027_Decommissioning%20of%20the%20San%20Onofre%20Nuclear%20Generating%20Station_Kaminske-Amabile-Harriman.pdf. 14 Id. 15 Id. 16 Id. 17 U.S. NRC, NRC: NMSS - State Regulations and Legislation, https://scp.nrc.gov/rulemaking.html#CA. 18 Id.

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the California Department of Public Health administers and enforces the laws that are implemented through the agreement.19

In California, any applicant, other than a Federal agency or Federally-recognized Indian tribe, who wishes to possess or use licensed nuclear or radioactive material in the state works directly with the California Department of Public Health in order to prepare a license application to use or possess nuclear materials within the state. The applications are then filed with The California Department of Public Health, not with NRC.20 Please look to the California Department of Public Health section for more information regarding the state's role in licensing and inspecting nuclear materials.

2. California Coastal Commission The CCC is responsible for permitting SONGS onshore and offshore activities through a Coastal Development Permit (CDP). A CDP is generally required when there is any development activity in the Coastal Zone.21 SONGS is located in the Coastal Zone, so any construction, repair, or maintenance activities that result in a change to the size or environmental impacts of SONGS require a CDP issued by the CCC.22 This includes the Independent Spent Fuel Storage Installation (ISFSI) expansion, which was approved by the CCC in 2015.23 The CCC has some control over the SNF at SONGS. If the SNF has not been transferred to an off-site location by 2035, the CCC may determine that the approved ISFSI needs to be moved.24 Under that scenario, the approved ISFSI would have to be relocated to a yet to be determined location.25 This would include the packaging and shipping of SNF off-site, likely to a permanent repository or interim storage facility, which currently is unavailable.26

3. California State Lands Commission The California SLC has jurisdiction over the offshore SONGS structures, which are within state public trust lands. These structures include "SONGS Units 2 and 3 offshore intake and discharge conduits and associated appurtenances; navigational and environmental monitoring buoys; and riprap along the shore seaward of the ordinary high-water mark."27 Originally, the SLC's jurisdiction included leasing the offshore land to SCE to operate SONGS during its operating period. Currently, SLC's jurisdiction includes

19 See 27 FR 3864, Notice of Agreement with the State of California (April 21, 1962). Available

here: https://scp.nrc.gov/special/regs/caagreements.pdf; see also U.S. NRC, Directory of Agreement State and Non-Agreement State Directors and State Liaison Officers, https://scp.nrc.gov/asdirectory.html#CA. 20 21 CCC CDP Pamphlet. Available here: https://www.coastal.ca.gov/enforcement/cdp_pamphlet.pdf. 22 Id. 23 CCC CDP # 9-15-0228. 24 California State Lands Commission, SONGS Unit 2 & 3 Decommissioning Project Final EIR, ES-5 (Feb. 2019).

Available here: https://www.slc.ca.gov/wp-content/uploads/2019/02/SONGS_ExecSumm_Final.pdf. 25 Id. 26 Id. 27 Id. at ES-1.

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leasing the offshore land to SCE for the SONGS decommissioning activities.28 Because SLC authorized the offshore SONGS components by leasing the offshore land to SCE, SLC is responsible for the state-level environmental review of those components.29 This environmental review is done via an Environmental Impact Report (EIR) pursuant to the California Environmental Quality Act (CEQA).30 The EIR must identify and analyze all of the environmental impacts of the SLC lease, and, if feasible, the EIR must state how significant environmental impacts will be mitigated.31 Lastly, under the SLC lease, the offshore land must be restored to pre-lease conditions once decommissioning is completed (SCE is currently in the decommissioning process).32

4. California Department of Public Health - Radiologic Health Branch The Radiologic Health Branch (RHB) is within the Radiation Safety and Environmental Management Division of the California Department of Public Health.33 The RHB enforces the California state laws and regulations designed to protect the public, radiation workers, and the environment.34 Enforcing these laws and regulations are part of California's responsibilities as an NRC Agreement State. The RHB is also responsible for providing public health functions associated with administering a radiation control program.35 Pursuant to RHB's responsibilities, RHB conducts routine monitoring of radioactive materials in the environment, including radioactive materials in media such as air, milk, food, and water.36 This includes air sampling for radioactivity at SONGS.37

5. California Public Utility Commission

The California Public Utilities Commission (CPUC) regulates utilities that own nuclear power plants in the state, such as SCE.38 On the federal level, the NRC requires nuclear power plants to set aside funds for

28 Id. 29 Id. 30 Id. 31 California State Lands Commission, The State Lands Commission’s Role in SONGS Decommissioning: Public Trust

and CEQA Public Review (PowerPoint), https://www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/20181/State%20Lands%20Commissions%20Role%20in%20SONGS%20Decommissioning.pdf. 32 Id. 33 California Department of Public Health, Radiologic Health Branch,

https://www.cdph.ca.gov/Programs/CEH/DRSEM/Pages/RHB.aspx. 34 Id. 35 Id. 36 See California Health and Safety Code section 114755; California Department of Public Health, Radiologic Health

Branch, https://www.cdph.ca.gov/Programs/CEH/DRSEM/Pages/RHB.aspx. 37 California Department of Public Health, Radiologic Health Branch,

https://www.cdph.ca.gov/Programs/CEH/DRSEM/Pages/RHB.aspx. 38 The California Public Utilities Commission, https://www.cpuc.ca.gov/default.aspx. The CPUC mandates are

represented in the following CPUC program areas: electric costs, electric power procurement and generation, energy infrastructure, customer energy resources, energy efficiency, energy advice letter and tariff information, electric rates, and natural gas and oil pipeline regulation. https://www.cpuc.ca.gov/energy/.

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decommissioning while the power plant is operating.39 The CPUC allowed SCE to collect the NRC-required decommissioning funds during SONGS' operating years.40 The money was collected from customers and invested in dedicated trusts.41 SCE estimates that the $4.4 billion decommissioning project will be fully funded through the already collected CPUC-approved customer contributions.42 D. Federal government and agencies

1. Congress As the lawmaking branch of the federal government, the U.S. Congress can pass a law that mandates (beyond what the NWPA already mandates) off-site interim storage of SNF or a repository for the permanent disposal of SNF. Furthermore, Congress provides funding through appropriations bills for discretionary spending that goes toward NRC's licensing process for consolidated interim storage (CIS) facilities or permanent repositories.43 If the NRC were to grant a license for a CIS facility or a repository, then Congress would also have to appropriate funds for the CIS facility's or repository's construction and operation.44

2. Trump Administration a. EPA The EPA is responsible for establishing standards for the protection of human health and the environment from radioactive materials.45 EPA standards set protective limits on the radioactivity in soil, water, and air that comes from human uses of radioactive elements—including the storage and transportation of SNF.46 EPA also issues federal guidance documents with recommendations for radiation protection.47 Furthermore, EPA develops technical reports to help standardize methods for radioactive dose and risk assessment.48 This guidance and the technical reports are used by federal and state agencies to develop radiation protection regulations and standards.49 EPA also helps state and local responders respond to radiological emergencies.50 Lastly, EPA develops science-based guidance for cleaning up sites that are contaminated with radioactive materials.51

39 SONGS Community, Decommissioning Funding, https://www.songscommunity.com/about-

decommissioning/decommissioning-san-onofre-nuclear-generating-station. 40 Id. 41 Id. 42 Id. 43 Stewart & Stewart, Solving the Spent Nuclear Fuel Impasse, 21 NYU Env'l. L..J. 1, 14 (2014). 44 Id. 45 EPA, EPA's Role in Radiation Protection, https://www.epa.gov/radiation/epas-role-radiation-protection. 46 Id. 47 Id. 48 Id. 49 Id. 50 Id. 51 Id.

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More specific to SNF and high-level radioactive waste, EPA sets environmental standards for spent fuel disposal.52 Specifically, the EPA regulations set standards for public protection from the management and disposal of SNF and nuclear waste at nuclear power plant facilities.53 The standards also apply to the management and storage of these materials at any facility operated by the DOE.54 The EPA regulations have three subparts. Subpart A limits the radiation exposure of members of the public from the management of SNF and radioactive waste prior to its disposal.55 Subpart B sets containment requirements for disposal systems, which limit the amount of radioactivity that may enter the environment for 10,000 years after facility closure.56 Subpart B also sets individual protection requirements, which limit the amount of radiation to which an individual can be exposed from an undisturbed repository.57 Subpart C includes ground water protection requirements that state that for 10,000 years after waste disposal, contamination in off-site underground sources of drinking water will not exceed the maximum contaminant level for radionuclides established by the EPA under the Safe Drinking Water Act.58 b. DOE The DOE has the major managerial responsibilities related to the transportation, consolidated storage, and disposal of nuclear waste in a permanent repository.59 The DOE also has the technical capacities related to nuclear fuel design; and cask and container research and development.60 Under the NWPA, the DOE is responsible for carrying out the permanent disposal of SNF in one or more repositories (this is yet to happen).61 However, the costs of disposal are the responsibility of the generators and owners of the SNF (e.g. SCE).62 The NWPA also authorizes the DOE to develop facilities for CIS, known as Monitored Retrievable Storage (MRS), to store spent nuclear fuel in the interim, pending completion of a repository.63 As stated above, the costs of disposing SNF are the responsibility of the utilities who generate the SNF. However, currently, the DOE pays monetary damages to utilities, like SCE, for breaching its NWPA responsibility to take the utilities' waste and store it in a CIS facility or dispose of it in a repository.64

52 40 CFR § 191 (Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear

Fuel and Transuranic Radioactive Wastes). 53 Id. 54 Id. This would apply to any future DOE operated consolidated interim storage (CIS) facility or a repository (other

than Yucca Mountain because there is an exception for Yucca Mountain). 55 40 CFR §§ 191.01–.05. 56 40 CFR §§ 191.11–.17. 57 Id. 58 40 CFR §§ 191.21–.27. 59 See Stewart & Stewart, Solving the Spent Nuclear Fuel Impasse, 21 NYU Env'l. L..J. 1, 44 (2014); see also The

Nuclear Waste Policy Act of 1982 (42 U.S.C. 10101 et seq.). 60 See Stewart & Stewart at 44. 61 42 U.S.C. § 10131(a)(4). 62 Id. 63 Stewart & Stewart at 9. 64 Id. at 102.

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These damages are paid out of the federal "Judgment Fund" and go towards the costs incurred by the utilities for storing SNF.65 These costs include the materials and labor required for the construction and maintenance of new, at-reactor dry cask storage facilities.66 However, because payments from the Judgment Fund come out of the general federal Treasury, taxpayers are ultimately paying the cost of SNF storage.67

c. NRC The NRC, an independent regulatory commission, is the lead federal agency that regulates all aspects of commercial nuclear power plants in the United States.68 NRC's jurisdiction covers the storage, safety, and transportation of all SNF and nuclear waste within the United States.69 NRC's jurisdiction is often in conjunction with other federal, state, and local agencies. The NRC's major regulatory activities can be broken down into the following components: (1) regulation and guidance; (2) licensing, decommissioning, and certification; and (3) oversight.70 The NRC is also responsible for licensing and regulating the design, construction, operation, and eventual decommissioning of any DOE CIS or geologic repository for the permanent disposal of all high-level radioactive waste at Yucca Mountain in Nevada, which, up to this point, has been unsuccessful.71

i. Regulation and Guidance The NRC regulates commercial nuclear power plants and nuclear material throughout their life cycles by developing and issuing regulations that licensees must meet to obtain or retain a license or certificate to use nuclear materials or operate a nuclear power plant.72 The NRC regulations, found in Title 10 of the Code of Federal Regulations, cover the manufacture of nuclear power plant components, the operation of nuclear power plants, the storage of spent nuclear fuel, including ISFSIs, the packaging and transportation of nuclear material, and the applicable safety and environmental standards for all of these activities.73 To assist licensees in complying with all of the NRC regulations, NRC provides licensees various forms of regulatory guidance, which includes NRC's Inspection Manual.74

ii. Licensing, Decommissioning, and Certification The NRC licenses nuclear power plant activities throughout their entire lifecycle, from construction to operation to decommissioning to storage of SNF and nuclear waste. NRC also licenses the use and transport of nuclear materials, including nuclear waste, and issues certifications for the manufacture of all spent fuel casks, transportation packages, and reactor components.75 As for decommissioning, the

65 Id. 66 Id. 67 Id. 68 U.S. NRC, About NRC, https://www.nrc.gov/about-nrc.html; 42 U.S.C. § 5841(a)(1). 69 See 10 CFR §§ 1–171. Available here: https://www.nrc.gov/reading-rm/doc-collections/cfr/. 70 See U.S. NRC, How We Regulate, https://www.nrc.gov/about-nrc/regulatory.html. 71 See Nuclear Waste Policy Act of 1982 (42 U.S.C. 10101 et seq.). 72 See U.S. NRC, How We Regulate, https://www.nrc.gov/about-nrc/regulatory.html. 73 See 10 CFR §§ 1–171. Available here: https://www.nrc.gov/reading-rm/doc-collections/cfr/. 74 See U.S. NRC, How We Regulate, https://www.nrc.gov/about-nrc/regulatory.html. 75 Id.

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NRC is responsible for insuring that nuclear facilities are safely removed from service and that residual radioactivity is reduced to a level that allows termination of the operator's license.76

iii. Oversight NRC's oversight activities include inspections, which are done to verify that a licensee's activities are properly conducted to ensure safe operation in accordance with NRC's regulations.77 The NRC website states: “[d]uring active decommissioning, NRC inspectors may be at the facility 2 or 3 weeks of the month. During a long-term storage period, they would be present several times a year."78 The NRC Inspection Manual states: "[t]he inspection program also provides appropriate latitude for NRC management to administer, plan, and implement site-specific master inspection plans commensurate, in part, with licensee performance, site activities, and safety."79 Therefore, it seems that NRC has discretion as to how many inspections are required annually based on operator performance, status of the reactor, etc. The NRC is also responsible for responding to, and investigating, third-party allegations of licensee wrongdoing.80 If an inspection or investigation reveals a violation of an NRC regulation, then NRC enforces the regulations by issuing sanctions to the violating licensee(s).81

d. DOD Marine Corps Base Camp Pendleton, the land on which the onshore portions of SONGS sits, belongs to the Department of the Navy (DON), within the Department of Defense. SCE and DON entered into real estate agreements in which SCE was granted easements and leases in order to operate and now decommission SONGS on Camp Pendleton.82 The DON-owned land includes an approximately eighty-four-acre easement for the primary nuclear facilities; two leased parcels adjacent to the eighty-four-acre easement, including parking lots and laydown/storage land comprising approximately fifteen acres; and easements for an access road and rail spur.83 As part of the decommissioning process, the DON must conduct its own National Environmental Policy Act (NEPA) review. This review evaluates potential environmental impacts associated with DON's approval of a real estate agreement that extends the existing easements and leases to cover the decommissioning period. This review also establishes end-state requirements for the land, such as the subsurface removal options and final site restoration. The current easement expires in 2024.84

76 Id. 77 Id. 78 See NRC, Oversight of Materials and Reactor Decommissioning,

www.nrc.gov/waste/decommissioning/oversight.html 79 See NRC Inspection Manual, Chapter 2561, www.nrc.gov/reading-rm/doc-collections/insp-

manual/.../2003/imc2561.doc 80 Id. 81 Id. 82 California State Lands Commission, SONGS Unit 2 & 3 Decommissioning Project Final EIR, ES-1 (Feb. 2019). 83 Id. 84 SONGS Community, Environmental Oversight, https://www.songscommunity.com/about-

decommissioning/environmental-oversight.

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e. DOT Regulating the transportation of SNF and nuclear waste is the joint responsibility of the NRC and DOT. DOT's jurisdiction covers multiple aspects of transportation, including packaging, shipper and carrier responsibilities, and documentation for shipments of all levels of radioactive material.85 Essentially, DOT regulates all shipments of SNF and nuclear waste while they are in transit, and sets standards for labeling.86 DOT also provides oversight of vehicle safety, routing, shipping papers, emergency response, and shipper training.87 And, DOT carries out its own transportation inspection and enforcement programs.88 Regarding packaging, the greater the potential risk posed by a shipment's contents, the more stringent DOT’s packaging requirements are.89 Furthermore, DOT regulations limit how much radioactivity can be transported in each package to avoid a major disaster in the event of an accident.90 Lastly, DOT works with FEMA to oversee transportation-related emergency response coordination, training, and communication. f. FEMA FEMA (an agency within the Department of Homeland Security) is responsible for assisting Americans before, during, and after disasters. FEMA shares federal responsibility with NRC for radiological emergency planning and preparedness.91 FEMA's roles and responsibilities related to radiological emergency response include: (1) evaluating if state and local emergency plans are adequate to protect public health and safety; (2) evaluating if state and local emergency plans can be used by emergency response personnel; (3) evaluating if state and local emergency plans provide for sufficient resources and equipment during an emergency; (4) evaluating the alert and notification system for nuclear power plants; (5) responsibility for emergency preparedness training of state and local officials as a supplement to state, local, and utility efforts; (6) overseeing the development of the coordinated response of federal agencies to a nuclear power plant radiological emergency; and (7) reviewing the adequacy of emergency preparedness plans related to nuclear power plants, fuel facilities, and materials licensees.92

85 U.S. NRC, NRC Manual: Transportation of Radioactive Material, https://www.nrc.gov/reading-rm/basic-

ref/students/for-educators/11.pdf. 86 U.S. NRC, Materials Transportation, https://www.nrc.gov/materials/transportation.html. 87 U.S. NRC, NRC Backgrounder on Transportation of Spent Fuel and Radioactive Materials,

https://www.nrc.gov/docs/ML0504/ML050480314.pdf. 88 Id. 89 Id. 90 Id. 91 Memorandum of Understanding between NRC and FEMA, June 17, 1993 (58 FR 47996). Available here:

https://www.nrc.gov/about-nrc/emerg-preparedness/federal-state-local/44cfr353-7.pdf. 92 U.S. NRC, Federal, State and Local, and Tribal Responsibilities, https://www.nrc.gov/about-nrc/emerg-

preparedness/about-emerg-preparedness/federal-state-local.html.

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FEMA's responsibilities are carried out via the Radiological Emergency Preparedness (REP) Program.93 The REP Program coordinates the federal effort to provide state, local, and tribal governments with relevant and executable planning, training, and exercise guidance and policies necessary to ensure that adequate capabilities are in place to prevent, protect against, mitigate the effects of, respond to, and recover from incidents involving commercial nuclear power plants.94

3. Tribes Tribes play a minimal role in the storage, safety, and transportation of SNF and nuclear waste. Tribes have to be notified when nuclear waste is transported through their territories. NRC regulations require licensees to provide advance notification to participating Federally-recognized Tribal governments regarding shipments of SNF and nuclear waste that pass within or across Tribal territoires.95 In return, the tribal government is required to protect the shipment information provided to them.96 E. Licensee The licensee, or licensees, are the entities that generate and own the SNF. In this case, SCE is the licensee. Under the NWPA, the licensee has the primary responsibility to provide for, and pay for, interim storage of SNF until the SNF is accepted by DOE.97 This responsibility includes providing interim storage of SNF by maximizing, to the extent practical, the effective use of existing onsite storage facilities, and by adding new onsite storage capacity in a timely manner when necessary and practical.98 Currently, the SNF at SONGS is stored by SCE using two different storage systems: (1) spent fuel pools, which are enclosed, steel-lined pools; and (2) dry cask storage, which are sealed, stainless steel canisters that are housed in reinforced concrete structures. Because SCE remains responsible for the SNF until the SNF is accepted by DOE, it is in SCE's best interest to have the SNF relocated as soon as possible. To that end, SCE has acted in the interest of relocating SONGS SNF to an off-site storage facility.99 SCE has engaged a team of experts—the "Experts Team"—to advise SCE on any proposed relocation of SONGS SNF.100 SCE also issued a request for information through which SCE will select a consultant to support the development of a "Strategic Plan" to assess the feasibility of relocating the SNF.101 The "Experts Team" will review, advise upon, and support SCE’s development of the "Strategic Plan."102

F. Conclusion

93 FEMA, Radiological Emergency Preparedness Program, https://www.fema.gov/radiological-emergency-

preparedness-program. 94 Id. 95 10 CFR § 71.97. 96 10 CFR § 73.37(f). 97 42 U.S.C. § 10131. 98 42 U.S.C. § 10151(a)(1). 99 SONGS Community, Offsite Storage, https://www.songscommunity.com/used-nuclear-fuel/long-term-storage. 100 Id. 101 Id. 102 Id.

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Multiple federal, state, and local entities have a significant role in the storage, transportation, and safety of spent nuclear fuel and nuclear waste at SONGS and other operating and decommissioning nuclear power plants around the country. The nature of each entity's jurisdiction will vary depending on the location and status of the nuclear power plant. For example, because SONGS is located on Camp Pendleton, the DON has played a large role as the reactor's landlord throughout its lifecycle. However, other power plants could be located on state- or federally-owned land, which would invoke different jurisdictional roles. Regardless of a nuclear power plant's location and status, the NRC is the lead agency that regulates, licenses, and oversees the storage, transportation, and safety of SNF and nuclear waste. Because safely storing and transporting nuclear fuel is a complex and slow process, it is not surprising that the NRC works with other federal, state, and local entities to provide multiple layers of oversight and regulation.

1 July 2019

Self-Assigned Surfrider Foundation Question (2) What are potential impacts on the ISFSI and canisters if directly exposed to saltwater or groundwater?

Research conducted by Katie Day, Staff Scientist, Surfrider Foundation, for the Technical Advisory

Committee of Congressman Mike Levin’s, CA-49, SONGS Task Force.

Disclaimer: This review relied heavily upon information provided by the Holtec HI-STORM UMAX Final Safety Evaluation Report (FSAR) and HI-STORM FW FSAR. The FSAR’s provide non-location specific evaluations of the waste storage systems, and often allow alternative “replacement materials” to be utilized for many of the processes described below, which could vary in their corrosion resistance levels. Where available, additional information specific to the processes and structures utilized at the San Onofre Nuclear Generating Station (SONGS) is provided and assessed. Abstract Due to the immediate coastal location and subterranean design of the San Onofre Nuclear Generating Station (SONGS) Holtec Independent Spent Fuel Storage Installation (ISFSI), the proximity of this structure to both seawater and groundwater is concerning. The base of the ISFSI sits 8.5 feet above the ground water table at mean lower low water level (MLLW), yet at mean higher high, the ground water table could be notably higher. Over the next 50 years, coastal hazards, including exacerbated storms, coastal erosion, sea level rise, groundwater level rise and seawater intrusion into groundwater aquifers could cause the Holtec ISFSI to be directly exposed to seawater and/or freshwater. Understanding the impacts and risks to the ISFSI from water exposure is important to determine the current and future structural integrity of the facility. This review summarizes the potential impacts the Holtec ISFSI could experience from seawater or freshwater exposure, based on information provided by Holtec Final Safety Evaluation Reports and supplemental information provided by Southern California Edison (SCE) representatives. Materials reviewed include reinforced concrete, the Vertical Ventilated Module (VVM)’s Cavity Enclosure Container (CEC), and the Multi-Purpose Canister (MPC). Based on this review, potential impacts to the ISFSI and canisters from direct groundwater or seawater exposure that warrant further analysis include: (1) reduced structural integrity of the concrete “monolith” due to corrosion induced spalling from uncoated rebar in reinforced concrete, (2) corrosion of exposed carbon steel of the CEC divider shell after coating is scratched during canister downloading, (3) lack of an enclosure wall to further avoid groundwater intrusion, (4) chloride induced stress corrosion cracking on the MPC and (5) general corrosion of the MPC due to scratching of the chrome-oxide layer during downloading. Additional information on the ISFSI components and issues listed above should be requested to determine the risk to the Holtec ISFSI from water exposure, including clarification on any coatings or sealants used at SONGS, and the level of corrosivity of sediment adjacent to the SONGS ISFSI. Introduction The San Onofre Nuclear Generating Station (SONGS) is in the process of decommissioning, and has 3.6 million pounds of spent fuel onsite. During decommissioning, spent fuel assemblies are transferred from cooling pools to dry storage, called an Independent Spent Fuel Storage Installation (ISFSI), to undergo passive cooling. Waste will remain stored in the ISFSI until federal agencies determine an offsite interim storage location or permanent repository for the waste, or until state agencies refuse to award or

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extend Coastal Development Permits. There are two ISFSI facilities at SONGS; the Areva ISFSI, previously constructed and loaded; and the Holtec ISFSI, constructed in 2017 and in the process of being loaded with 73 canisters. Due to the immediate coastal location and subterranean design of the Holtec ISFSI, the proximity of this structure to both seawater and groundwater is concerning. The base of the ISFSI currently sits 8.5 feet above the ground water table at mean lower low water level (MLLW),1 at mean higher high, the ground water table could be notably higher. Over the next 50 years, coastal hazards, including exacerbated storms, coastal erosion, sea level rise, groundwater level rise and seawater intrusion into groundwater aquifers could cause the Holtec ISFSI to be directly exposed to seawater, groundwater and heavy rain events. Understanding the impacts and risks to the ISFSI from water exposure is important to determine the current and future structural integrity of the facility. This review summarizes the potential impacts the Holtec ISFSI could experience from seawater or freshwater exposure, based on information provided by the Holtec HI-STORM UMAX Final Safety Evaluation Report (herein referred to as “UMAX FSAR”), Holtec HI-STORM FW FSAR (herein referred to as “FW FSAR”) and information provided by Southern California Edison (SCE) representatives. Materials reviewed include reinforced concrete, the Vertical Ventilated Module (VVM)’s Cavity Enclosure Container (CEC), and the Multi-Purpose Canister (MPC).

(1) Concrete Concrete is used for many purposes at the SONGS Holtec ISFSI. To narrow what impacts to consider for this analysis, it was important to first understand the use, structure, and services of concrete at the ISFSI. In general, concrete is used for backfill, a barrier against water seepage, shielding from radiation, structural stability and resiliency against missile impacts and seismic events.

A. Use of Concrete at SONGS Holtec ISFSI According to the UMAX FSAR, concrete is used as the material for five main structures. Descriptions are provided by excerpts for each of the structures below.2

i. ISFSI Pad “ISFSI Pad means the reinforced concrete pad that provides the support surface for the cask handling device… to augment shielding, to provide a sufficiently stiff riding surface for the cask transporter, to act as a barrier against gravity-induced seepage of rain or floodwater around the VVM body as well as to shield against a missile. The ISFSI pad is a monolithic reinforced concrete structure that provides the load bearing surface for the cask transporter”

ii. Support Foundation Pad “Support Foundation Pad (SFP) means the reinforced concrete pad located underground on which the CECs are situated… The SFP and the under-grade must have sufficient strength to support the weight of all the loaded VVMs during long-term storage and earthquake conditions.”

1 See US NRC email to Tom Palmisano, dated May 22, 2017. Subject: SAN ONOFRE NUCLEAR GENERATING STATION – NRC INSPECTION REPORT 05000206/2016004, 05000361/2016004, 05000362/2016004, AND 07200041/2016002 2 See https://www.nrc.gov/docs/ML1619/ML16193A339.pdf

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iii. Self-hardening Engineered Subgrade (SES or CLSM) “The lateral space between each CEC, the SFP and the ISFSI pad is referred to as the subgrade and is filled with a Controlled Low-Strength Material (CLSM). Alternatively, ‘lean concrete’ may also be used. CLSM is a self-compacted, cementitious material used primarily as a backfill in place of compacted fill… The space below the SFP is referred to as the under-grade. ACI 116R-00 defines lean concrete as a material with low cementitious content. CLSM and lean concrete are also referred to as ‘Self-hardening Engineered Subgrade (SES).”

iv. Closure Lid “The Closure Lid is a steel structure filled with plain concrete that can withstand the impact of the Design Basis Missiles defined in Chapter 2… To minimize the radiation emitted from the storage cavity, a portion of the Closure Lid extends into the cylindrical space above the MPC. This cylindrical below-surface extension of the Closure Lid is also made of steel filled with shielding concrete to maximize the blockage of skyward radiation issuing from the MPC… Concrete, which serves strictly as a shielding material in the Closure lid, is completely encased in steel.”

v. Optional Enclosure Wall: Not used at SONGS Holtec ISFSI “The Enclosure Wall is an optional structure which may be utilized to mitigate groundwater intrusion at sites with a high water table. Analyses in Chapter 3 show that the Self-hardening Engineered Subgrade (SES) provides a stable lateral support system to the ISFSI under the Design Basis Earthquake. In the absence of an Enclosure wall, the interface between the SES and the native subgrade defines the radiation protection boundary of the ISFSI.” SCE did not opt to construct an Enclosure Wall at the SONGS Holtec ISFSI.3

B. Services of Concrete at SONGS ISFSI These concrete structures provide three main services to the ISFSI, which include additional radiation shielding, both lateral and vertical; structural stability under various weight loads; and ability to withstand design-based earthquake and missile threats. Explicit reference to these services are provided by excerpts from the FSAR below.

i. Radiation Shielding “Steel, concrete, and the subgrade are the principal shielding materials in the HI-STORM UMAX. The steel and concrete shielding materials in the Closure lid provide additional gamma and neutron attenuation to reduce dose rates.”

ii. Structural Stability of ISFSI “The soil lateral to the CECs (termed Space A in this FSAR) is required to be removed and replaced with a Self-hardening Engineered Subgrade (SES) such as CLSM or lean concrete which imparts enhanced structural characteristics to the ISFSI pad support system improving its ability to support the Casktransporter during MPC transfer operations. The minimum average density and the minimum shear wave velocity in the lateral subgrade surrounding the VVMs have been specified in Table 2.3.2”

3 Information provided during phone conversation with Ron Pontes, Manager SONGS Decommissioning Environmental Strategy

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iii. Ability to Withstand Earthquake and Missile Threats (Design Based) “The subgrade must continue to maintain its physical integrity under the DBE load combination in Table 2.4.3. Maintaining physical integrity means no structural collapse, instability or cracks that produce an unobstructed direct streaming path in the subgrade for the radiation emanating from the stored fuel, and no constriction of the CEC that may interfere with retrievability of the MPC. b. In the scenario where the adjacent subgrade has been excavated exposing the lateral surface of the subgrade and a Design Basis Missile (see Table 2.3.3) strikes the exposed surface in the most severe orientation, the sub grade must be capable of stopping the missile before it reaches the MPC… To meet increased seismic inertia loads, the strength of the material in the interstitial space between the VVMs (Space A in Figure 2.4.4) is increased by using normal density concrete. The minimum compressive strength of the Space A concrete is provided in Table 2.3.10”. For earthquakes specifically, “[t]he fill material interstitial space between the CECs, referred to as Space A in Figure 2.4.4, is replaced with plain concrete with a minimum compressive strength of 3000 psi”.

C. Impacts to ISFSI Concrete from Water Exposure While Holtec and Southern California Edison (SCE) frequently refer to the Holtec ISFSI as a “monolithic” structure, concrete is not actually monolithic. Concrete is highly heterogeneous, often made of a mix of gravel, sand, cement, water, air and additives.4 Though concrete may look like one solid structure, it is filled with air pockets and pores caused by the evaporation of water from the initial mix.5 The size, amount and connectivity of the pores can directly impact the structural integrity of the structure. This is especially the case with reinforced concrete, where pore size and connectivity can contribute to the potential oxidation, or corrosion, of the “reinforcing steel”, and ultimately reduce the stability and integrity of the structure. The pore size distribution, connectivity and total porosity is often determined by the “Water-Cement Ratio” of the concrete.6 The ISFSI Pad and Support Foundation Pad at SONGS both utilize reinforced concrete. Reinforced concrete means that the concrete is lined with steel bars (often rebar) to add strength to the structure. Unfortunately, rebar is an unstable metal and will chemically recombine with elements to return to its natural, stable state of iron, a process called oxidation, rust and/or corrosion. According to Kepler et al,7 concrete pore water solution has a relatively high pH (generally greater than 11) which forms an oxide layer on the contained rebar, making the rebar “passive”. This layer naturally protects the rebar from direct oxygen exposure. If the pH is sufficiently reduced or there is an increase in chloride ions (such as from saltwater), this layer can be broken. In areas with oxygen and water exposure, this could lead to significant corrosion. In conducive environments, again such as saltwater, dissolved chloride can induce an “iron chloride complex” causing enhanced corrosion through electrochemical processes (formation of an electrochemical cell), either between the steel rebar and the concrete pore solution, or between materials within the steel itself, especially if that steel has been scratched. Both instances can lead to tensile stresses on the concrete, causing cracking and eventual spalling, where large chunks of the concrete actually break off. The more interconnected the pores in the concrete, the faster this voltage induced corrosion can occur.8 Other risks to reinforced concrete from water exposure

4 See https://www.researchgate.net/publication/275350234_Concrete_technology_-_porosity_is_decisive 5 See https://www.researchgate.net/publication/275350234_Concrete_technology_-_porosity_is_decisive 6 See https://www.hindawi.com/journals/amse/2014/273460/ 7 See http://www2.ku.edu/~iri/projects/corrosion/SM58.PDF 8 See http://www2.ku.edu/~iri/projects/corrosion/SM58.PDF

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include surface scaling, which is a loss of surface mortar often caused by freeze-thaw reactions; delamination9; and brittle fracture in low temperatures. It is unclear if the SES used for the subgrade between each VVM at SONGS is made from lean concrete or CLSM, or if one material is more resistant to porosity than the other. The SES is not a form of reinforced concrete because it does not contain rebar; however, this material fills gaps between the steel VVMs, meaning its porosity may have an impact on the corrosion risk of the interior steel components (CEC’s), just as the porosity of the reinforced ISFSI Pad and Support Foundation Pad could have an impact on the corrosion risk of the contained rebar. Based on the information collected during this review, corrosion of reinforcing metals from water intrusion through porous concrete, and subsequent spalling or cracking of the concrete, is the main threat that water exposure poses to reinforced concrete at the Holtec ISFSI. This is important as concrete provides important services at the ISFSI, including radiation shielding, structural stability and ability to withstand seismic and missile events. It will be important to get specific information on the total porosity and pore connectivity of the SES, ISFSI Pad and Support Foundation Pad to determine water permeability through the “concrete monolith”.

D. Methods to Prevent Spalling and Other Risks to Reinforced Concrete Galvanic corrosion is one form of protecting reinforcing steel from corrosion, and therefore protecting the integrity of the reinforced concrete structure as a whole. Galvanic corrosion directs corrosive currents to another, more negatively charged metal alloy, thus protecting the more positively charged metal. Generally, when it comes to steel; zinc, aluminum, and magnesium are more negatively charged, while copper and stainless steel are more positively charged. Other options to prevent corrosion induced cracking or spalling of reinforced concrete is by adding a water sealant to the concrete surface, adding a protective coating to the rebar (such as epoxy), or by using an Impressed Current Cathodic Protection System (ICCP), which is flowing a charged current to the metal. In the Holtec FSAR, there is no discussion on concrete porosity or mention of methods to mitigate corrosion of reinforced concrete in the Support Foundation Pad (below the VVMs) or the ISFSI Pad (above the VVM’s), which both contain rebar. SONGS does not utilize many of the above mentioned corrosion mitigation techniques, including rebar coatings, concrete sealants or ICCP.10 It is explicitly mentioned in the UMAX FSAR that “corrosion of structural steel embedded in the concrete structures due to salinity in the environment at coastal sites is not a concern for HI-STORM UMAX VVM because it does not rely on rebars (indeed, it contains no rebars).” This is in reference to the SES/ CLSM fill that surrounds the VVM CEC shells. However, the UMAX FSAR later refers to the SES as a concrete encasement that could be reinforced: “[r]egardless of reinforcement method, the material selected shall be corrosion-resistant or otherwise appropriately coated (e.g., epoxy coated steel wire) for corrosion resistance.” A representative at SCE confirmed that the rebar used in the Support Foundation Pad and ISFSI pad are not coated.11 It seems the only corrosion protection of reinforcing steel is from the

9 See https://www.buildingforensicsintl.com/concrete-delamination-damage 10 Information provided during phone conversation with Ron Pontes, Manager SONGS Decommissioning Environmental Strategy 11 Information provided during phone conversation with Ron Pontes, Manager SONGS Decommissioning Environmental Strategy

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cathodic protection provided by the high alkalinity of concrete, which could be disturbed by seawater or salty groundwater exposure. Additionally, since the SES encases metal VVM’s, it should be explored if corrosion of VVM’s could cause cracking and scaling of the SES, similar to the impacts from corrosion of reinforcing steel. The UMAX FSAR states that “[a]ll exposed surfaces of the HI-STORM UMAX VVM components are made from stainless steels or ferritic steels that are readily painted. Concrete, which serves strictly as a shielding material in the VVM Closure Lid, is encased in steel. Therefore, the potential of environmental vagaries such as spalling of concrete are ruled out for HI-STORM UMAX VVM.” Getting additional assurance that this statement applies to SONGS is recommended. The UMAX FSAR table below (p. 8-12) references CLSM performance properties. To note, the pH of the CLSM is said to range as low as 7.5, which may not be high enough to create a passive layer to protect the encased metal alloys (literature ranges based on type of steel and chloride content, but it’s frequently referenced that the pH must be 10.5 or greater for steel passivity to occur)12. In discussion of corrosion protection for the CEC, design standards from ACI 318 are required to be deployed for the SES, yet again this is not explicitly mentioned for the reinforced concrete used for the Support Foundation Pad or ISFSI Pad.

Table 1. Additional CLSM Performance Properties. Source: UMAX FSAR, p. 8-12.

In regards to seismic risk from cracked concrete, the LS-DYNA SSI analysis on a design basis earthquake (DBE) “only considers the governing uncracked concrete condition” of concrete. However, the FSAR also states that previous analysis on “cracked scenarios” found that “[t]he DBE analysis results summarized in Table 3.4.3 consistently demonstrate that the key seismic response (i.e., the seismic impact loading on the SFP) under the uncracked condition is bounding”. (2) Cavity Enclosure Container (CEC) The Cavity Enclosure Container (CEC) is defined in the UMAX FSAR as a “thick walled cylindrical steel weldment that defines the storage cavity for the MPCs”. More specifically, it is described as:

12 See https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5457108/

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[A] weldment of the Container Shell, Container Flange, Bottom Plate, Lower MPC Guides, and MPC Bearing Pads. The Closure Lid is a weldment of structural steel encasing plain concrete and arranged to provide an appropriate outlet passage for the heated air issuing from the storage cavity. An insulated Divider Shell with Upper MPC Guides is situated within the CEC and restrained by the Lower MPC Guides at the bottom and by the Container Flange at the top. These individual components are collectively referred to as VVM Components.

Each canister (MPC) is downloaded into a pre-installed CEC in the Holtec ISFSI. The CEC contains a divider shell that bifurcates the area between the canister and CEC as either down-flow or up-flow of air for passive cooling. The divider shell has insulation to help prevent preheating of the cool down-flow air, which is said to be “water and radiation resistant” yet the exact material is not provided. The CEC, along with the closure lid, is referred to as the Vertical Ventilated Module (VVM). The VVM is described as providing “structural protection, cooling, and radiological shielding for the MPC.”

A. Materials and Design of the CEC The CEC is referenced in the UMAX FSAR as a thick walled weldment, yet the thickness of the CEC containment shell is said to be just 0.75 inches, with a baseplate of 1.5 inches thick (p.5-30). Components of the CEC are said to be made out of carbon steel in the Holtec FSAR. However, an SCE representative confirmed that almost all of the CEC components are made out of stainless steel (type 304) at SONGS; including the Container Shell, Bottom Plate, Lower MPC Guides, Upper MPC Guides, MPC Bearing Pads, Closure Lid, and Container Flange. Stainless steel was used to provide stronger corrosion resistance. Only the divider shells are made out of carbon steel. The CEC is welded at the bottom, providing a physical barrier preventing water penetration from the bottom or sides; however, the top of the CEC is open when the closure lid is open. Even when the closure lid is on, the lid has air vents to allow for passive cooling, so the CEC is never completely sealed. The UMAX FSAR states that there is sloping on the ISFSI pad to divert water away from the CEC vents and into the storm drain system, but heavy rainstorms or flood events may still result in water entering the CEC air ducts and have direct contact with the MPC. Any water that enters the CEC will remain contained in the CEC unless explicitly pumped out. However, “[t]he cutouts in the Divider Shell are sufficiently tall to ensure that if the cavity were to be filled with water, the bottom region of the MPC would be submerged for several inches. This design feature is important to ensure adequate thermal performance of the system if flood water would stop air flow”. To note, the UMAX FSAR states that “all HI-STORM MPCs are designed to withstand 125 feet of water submergence (Table 2.4.1). The VVM will clearly withstand this static head of water above the surface of the ISFSI because all structural members are either not subject to any pressure differential from the flood or are backed by the subgrade, which resists the flood water directly.” Regarding pressure, the Holtec FSAR explains that submergence of the CEC to the “Container Flange” is not at risk to hydrostatic pressure so “potential for significant stresses is not a concern”. Buoyancy is not also not a concern due to the dead weight of the system. There is no discussion of increased risk to corrosion of the CEC or VVM from water submergence. Blockage of air vents caused by debris from flood events is a noted risk, which is why the visual inspection of air vents and/or monitoring of heat loads at air vents is critical. A system pre-established

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and approved to remove extensive debris from CEC vaults and vents would be a recommended contingency plan. “…[t]he water could enter the inlet ducts and block portion or the entire cooling air flow passageway at the bottom of the cavity, which reduces the air flow ventilating through VVM and causes an elevation of the fuel cladding temperature and system component temperatures”, including “overheating of the concrete in the overpack”.

B. Methods of Corrosion Resistance for CEC Components Methods to resist corrosion on the VVM CEC vary by component, and according to the UMAX FSAR range from zinc coatings, reliance on pH protection from concrete encasement, or use of stainless steel. Metal types used on the CEC may include “SA516 Gr. 70, SA515, Gr. 70, [and] SA36 or austenitic stainless steel.” Coatings and ICCP are required depending on the level of “environment corrosivity” which is determined by soil testing. It is unclear what the level of soil corrosivity is at SONGS, but it is expected to be highly corrosive due to coastal proximity. Since SCE opted to use SES as infill between VVMs, instead of natural soil, it would be beneficial to confirm if soil corrosivity requirements still apply. Specifics on corrosion mitigation techniques used for various components are provided below, often by relevant excerpts from the UMAX FSAR.

i. Carbon Steel Components (the Divider Shell) “Except for the CEC exterior surfaces (exterior CEC surface coating requirements discussed separately), all carbon steel surfaces of the VVM are lined and coated with the same or equivalent surface preservative that is used in the aboveground HI-STORM FW and HI-STORM 100 overpacks. The pre-approved surface preservative is a proven zinc-rich inorganic/metallic (may also be an organic zinc rich coating) material that protects galvanically and has self-healing characteristics for added protection. All exposed surfaces interior to the VVM are accessible for the reapplication of surface preservative, if necessary” (UMAX FSAR). Interestingly, the UMAX FSAR states that “[c]hloride corrosion is not a concern since chloride leachables are limited and sufficiently low”, yet this may not apply when exposed to chloride ions in saltwater. An SCE representative confirmed that there are no coatings added to components made out of stainless steel, except for those stainless steel components that are directly welded to the carbon steel Divider Shell, such as seismic restraints. The Divider Shell and the stainless steel components welded to the Divider Shell are coated with a Carbonic Zinc 11, Sherwin Williams Zinc Clad II HS, or Sherwin Williams Zinc Clad II Plus. The risk from canister to CEC scratching during loading or seismic events should be considered, as its important to ensure that the coating does not get penetrated, and if so, that it is able to sufficiently self-heal.

ii. Foil and Jacketing “Stress corrosion cracking of the foil or jacketing, whether made from stainless steel or other material, is not an applicable corrosion mechanism due to minimal stresses derived from self-weight. The foil or jacketing and attachment hardware shall either have sufficient corrosion resistance (e.g., stainless steel, aluminum, or galvanized steel) or shall be protected with a suitable surface preservative” (UMAX FSAR).

iii. Bolts and Fasteners “All bolts and fasteners are made of alloy materials which are not expected to experience any significant corrosion in the operating environment. The ISFSI operation and maintenance program shall call for

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coating of bolts and fasteners if the ambient environment is aggressive. All threaded surfaces are treated with a preservative to prevent corrosion. The O&M program for the storage system calls for all bolts to be monitored for corrosion damage and replaced, as necessary” (UMAX FSAR). Clarification on both the determination of the ambient environment at SONGS and use of coatings bolts and fasteners is recommended.

iv. CEC Shells CEC shells are made out of austenitic stainless steel. Stainless steel is a type of steel that’s been “passivated”, where the surface oxidizes with chromium to create a protective layer, referred to as a “chrome-oxide” layer.13 While this layer makes stainless steel corrosion-resistant in coastal environments, it is still able to experience corrosion if submerged in saltwater. The UMAX FSAR acknowledges “peeling or perforation of surface preservatives on steel surfaces and corrosion to exposed steel surfaces” as potential degradation modes to the VVM in Table 8.1.12. This clarifies that exposed steel surfaces are also at risk to corrosion. Additionally, “[t]he exterior surfaces of the CEC are in contact with either engineered fill or concrete (concrete encasement or “free-flow “concrete ) and may be subjected to cathodic protection, as applicable.” As such, the plain concrete surrounding the stainless steel VVM CEC shell is considered as a form of corrosion mitigation. The UMAX FSAR also states that the CEC “is substantially sequestered from the native soil through two engineered features: a. A thick reinforced concrete Enclosure Wall surrounds the VVM array and, along with the Support Foundation pad, provides a physical separation (water intrusion protection) to the CECs. b. The subgrade in contact with the CECs is either a “free flow” concrete or an engineered fill selected to provide a non-aggressive environment around the CECs.” The Enclosure Wall was not constructed at SONGS. The referenced concrete or engineered fill is the SES/CLSM, which is also referred to as the 5 inch-thick “CEC concrete encasement”, protects against corrosion by providing a pH buffering effect. This is thicker than the ACI 318 recommendation to use a minimum of 3-inch thick concrete to protect reinforcing metals in “aggressive environments”. Mechanisms to minimize voids and micro-cracks are said to be required to be deployed, but specifics are not provided, and it would be beneficial to ensure that these mechanisms are utilized at SONGS.

v. CEC Lid “All exposed surfaces of the HI-STORM UMAX VVM components are made from stainless steels or ferritic steels that are readily painted. Concrete, which serves strictly as a shielding material in the VVM Closure Lid, is encased in steel. Therefore, the potential of environmental vagaries such as spalling of concrete are ruled out for HI-STORM UMAX VVM” (UMAX FSAR).

vi. Impressed Current Cathodic Protection System (ICCPS) “If the aggressiveness of the subgrade around the CEC is highly aggressive and warrants an ICCPS then the user may choose to either extend an existing ICCPS to protect the installed ISFSI, or to establish an autonomous system. The initial startup of the ICCPS must occur within one year after installation of the VVM to ensure timely corrosion mitigation. In addition, the ICCPS should be maintained operable at all times after initial startup except for system shutdowns due to power outages, repair or preventive maintenance and testing, or system modifications. Because there are a multitude of ISFSI variables that

13 See https://www.mgnewell.com/wp-content/uploads/2016/11/Passivation-of-stainless-steel.pdf

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will bear upon the design of the ICCPS for a particular site, the essential criteria for its performance and operational characteristics are set down in this FSAR, which the detailed design work for each ISFSI site must follow” (UMAX FSAR). To note, ICCPS is not a passive management technique, as it provides corrosion protection by flowing an electrical current through the surrounding structure (so in this case, the SES) and on to the metal. An ICCPS is not being utilized at the SONGS Holtec ISFSI. Tables 8.1.2 to 8.1.4. Stated degradation modes to VVM, including the mechanism and area affected. Source: UMAX FSAR.

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(3) Multi-Purpose Canister (MPC) The MPC is defined as “the sealed canister consisting of a fuel basket for spent nuclear fuel storage, contained in a cylindrical canister shell (the MPC Enclosure Vessel). The MPC is the confinement boundary for storage conditions.” In other words, the MPC is the canister that is able to contain up to 37 spent fuel assemblies, and is the vessel that is lowered into the VVM of the ISFSI. Much of the information regarding degradation modes and mitigation to the MPC is listed in its original host docket (72-1032 for HI-STORM FW), not the UMAX FSAR. For the purpose of this self-assigned question for Congressman Levin’s Task Force, degradation modes from seawater and freshwater exposure are only reviewed for the surface of the canister; degradation modes of internal MPC materials are not considered.

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A. Materials of the MPC The MPC is made out of the austenitic stainless steel 316L. According to Table 8.1.3 of the UMAX FSAR, the external surface of the MPC is exposed to the ambient environment. Austenitic stainless steel 316L is one of the most corrosion-resistant stainless steel available, however, it is still prone to corrosion risk. The FW FSAR states that “[t]he confinement boundary is made of stainless steel material for its superior strength, ductility, and resistance to corrosion and brittle fracture for long term storage. The basket shims used to support the basket are made of a creep resistant aluminum alloy. The two-piece MPC lid is either made entirely of Alloy X or the bottom portion of the lid is made of carbon steel with stainless steel veneer.” More specifically, “[t]he available austenitic stainless steels are AISI Types 304, 304LN, 316 and 316LN containing a minimum of 16% chromium and 8% nickel, and at least traces of molybdenum. The passive films (formed due to atmospheric exposure) of stainless steels range between 10 to 50 angstroms (lxl0-6 to 5x10-6 mm) thick [8.12.4]. Of all types of stainless steels (i.e., austenitic, ferritic, martensitic, precipitation hardenable and two-phase), "the austenitic stainless alloys are considered the most resistant to industrial atmospheres and acid media" [8.12.4]. The MPC contains no gasketed, threaded, or packed joints for maintaining confinement. The all welded construction of the MPC confinement boundary and the inert backfill gas within ensures that the interior surfaces and the MPC internals (Metamic-HT baskets, shims, etc.) are not subject to corrosion. Exterior MPC surfaces would be exposed to the ambient environment while inside of a HI-STORM FW storage overpack or a HI-TRAC VW transfer cask.”

B. Impacts to MPC from Saltwater or Groundwater Exposure According to the UMAX FSAR and FW FSAR, the following failure modes that could result from water exposure were identified and details of the determined level of concern are provided by excerpts below. Note that no specific reference to submergence in the UMAX FSAR acknowledges added chloride ions from seawater exposure.

i. Thermal “Full or partial submergence of the MPC is not a concern from a thermal perspective, as discussed in Chapter 1, because heat removal is enhanced by the floodwater” (UMAX FSAR).

ii. Galling “Preventing galling of interfacing surfaces is another critical consideration in selecting bolt materials. Use of austenitic stainless bolts on interfacing austenitic stainless steel surfaces is not permitted. All threaded surfaces are treated with a preservative to prevent corrosion. The O&M program for the storage system calls for all bolts to be monitored for corrosion damage and replaced, as necessary” (FW FSAR).

iii. Corrosion and Pitting

Table 8.1.4 states that stress corrosion cracking of austenitic stainless steel is a failure and degradation mechanism of the MPC (UMAX FSAR). The FW FSAR also states that “[p]otential problems from general corrosion, pitting, stress corrosion cracking, or other types of corrosion, should be evaluated for the environmental conditions and dynamic loading effects that are specific to the component.” Based on the

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literature, corrosion methods of stainless steel include pitting corrosion, crevice corrosion, general corrosion, galvanic corrosion, stress corrosion cracking and intergranular attack. It is explicitly stated in the FW FSAR that “[c]asks deployed at coastal ISFSI sites that would be exposed to the harsh marine environment for prolonged periods must not suffer corrosion that will impair their functionality”. It is also stated that “[e]xtensive data show corrosion rates (pitting) to 0.00 18 (mm/yr) for 304, 304LN, 316 and 316LN in marine environments at ambient temperatures after 26 years [8.12.1]. Using this bounding corrosion rate data, a Holtec Position Paper [8.12.3] estimates the total corrosion of the external surface of the MPC in 100 years of service is about half a millimeter which is significantly smaller than the available design margins in the material thickness. It is to be noted that this upper-bound is estimated for an extreme hypothetical marine environment. As discussed earlier for inland applications the corrosion rates are insignificant. Therefore, corrosion of the MPC in long-term storage is not a credible safety concern.” The FW FSAR states that “[i]t is also recognized that moisture will not exist on the MPC exterior surfaces for many years since moisture will not condense on hot surfaces... It is estimated that it would take decades for the hottest MPC to approach ambient temperatures and once at ambient temperature, any MPC surfaces will be highly corrosion resistance even when wet.” As such, the FW FSAR states that “MPC surfaces are not coated”. MPC’s are located within the CEC, so cathodic protection from concrete exposure does not apply. There is no additional corrosion prevention methods used for MPC at SONGS, as the 316L steel is considered strongly resistant to corrosion, even in coastal environments. While this may suffice for ambient conditions, a change in corrosion risk from direct exposure to seawater must be considered, and does not seem adequately addressed in the FW FSAR or UMAX FSAR.

a. Concern Regarding Scratching Consideration of the change in corrosion risk due to scratching must be considered, as the UMAX FSAR states that “[d]eparture from the assumed values of material properties in the safety analyses can, in certain cases, adversely affect the computed safety margins”. In response to concerns regarding unapproved canister scratching from contact with the CEC during downloading, the NRC and SCE conducted an “Analysis of the Effects of Incidental Contact to Multipurpose Canisters During the Downloading Process”. This analysis measured the severity of scratches on eight of the 29 downloaded canisters at SONGS. Due to the use of laser peening during canister manufacturing, the canisters have a “a compressive stress field to a depth of at least 0.080 inches. Stress corrosion cracks cannot initiate or grow on surfaces with residual compressive stress.” Regarding the risk of pitting and general corrosion, “[c]ontact breaks through the chrome-oxide layer that protects stainless steel from pitting and general corrosion. However, any new surfaces exposed by wear marks are quickly (within weeks) covered by a newly formed chrome-oxide layer due the reaction of air with the chrome alloy in stainless steel. As a result, these wear marks will not have a significant effect on pitting and general corrosion rates.”14 Assurance that a chrome-oxide layer has re-established on all scratched canisters at SONGS is recommended to ensure that corrosion risk is not significantly increased due to scratching.

14 See https://scng-dash.digitalfirstmedia.com/wp-content/uploads/2019/06/Effects-of-Incidental-Contact-White-Paper-FINAL-060319.pdf

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iv. Brittle Fracture “Since stainless steel materials do not undergo a ductile-to-brittle transition in the minimum permissible service temperature range of the HI-STORM FW System, brittle fracture is not a concern for the MPC components” (FW FSAR). Conclusion The main threat to the structural integrity of the ISFSI concrete and VVM structures is contingent upon the porosity of the concrete, as water permeability through the structure and exposure to reinforcing steel or the CEC could cause corrosion and subsequent loss of structural integrity of the rebar, CEC, and concrete structure as hole. This could have impacts on the eventual retrievability of downloaded canisters due to reduced ability for the VVM and/or ISFSI Pad to withhold necessary weight loads, it could also reduce earthquake resilience and missile resilience. As mentioned in the UMAX FSAR “[t]he materials that comprise the dry spent fuel storage should maintain their physical and mechanical properties during all conditions of operations. The spent fuel should be readily retrievable without posing operational safety problems… Dry spent fuel storage protective coatings should remain intact and adherent during all loading and unloading operations within wet or dry spent fuel facilities, and during longterm storage”. Based on this review, notable potential impacts to the ISFSI and canisters from direct groundwater or seawater exposure include: (1) reduced structural integrity of the concrete “monolith” due to corrosion induced spalling from uncoated rebar in reinforced concrete, (2) corrosion of exposed carbon steel of the CEC divider shell after coating is scratched during canister downloading, (3) lack of an enclosure wall to further avoid groundwater intrusion, (4) chloride induced stress corrosion cracking on the MPC and (5) general corrosion of the MPC due to scratching of the chrome-oxide layer during downloading. Additional information on the ISFSI components and issues listed above should be requested to determine the risk to the Holtec ISFSI from water exposure, including clarification on any coatings or sealants used at SONGS, and the level of corrosivity of sediment adjacent to the SONGS ISFSI. While the FSARs determine that a 60 year design life and 100 year service life is expected for the Holtec ISFSI, including the VVM and reinforced concrete, the atmospheric and environmental conditions at the plant may warrant a request for more robust inspections of the ISFSI. As stated in the UMAX FSAR “ISFSIs located in areas subject to atmospheric conditions that may degrade the storage cask or canister should be evaluated by the licensee on a site-specific basis to determine the frequency for such inspections to assure longterm performance.” Suggested Further Analysis There are many approaches that could be used to identify impacts to the Holtec ISFSI from seawater and groundwater exposure. Due to time limitations, this review focused on consolidating degradation modes identified in relevant NRC Final Safety Analysis Reports and identifying potential issues not adequately addressed. Additional research methods to understand water impacts to the ISFSI could include reviewing case studies of similar structures overtime after water exposure, and conducting a more thorough literature review of research on each of the structural components of the ISFSI.

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Self-Assigned Surfrider Foundation Question (3) What are the risks from destroying cooling pools while nuclear waste is still on the site?

Research conducted by Katie Day, Staff Scientist, Surfrider Foundation, for the Technical Advisory

Committee of Congressman Mike Levin’s, CA-49, SONGS Task Force. Introduction The retention of a cooling pool is the only stated mechanism that could potentially be used to repackage spent fuel assemblies loaded and sealed in dry storage canisters for nuclear waste. The potential for a severe loss of canister integrity that would require repackaging is considered highly unlikely, and has yet to be needed for any of the over 2,000 canisters loaded to date in the United States. However, the extremely long half-life and environmental, economic and human health damages associated with potential exposure to radioactive waste, paired with the notably unstable environment at the San Onofre Nuclear Generating Station (SONGS) necessitates significant precautionary mechanisms to maintain onsite safety and assurance that waste remains transportable. This analysis identifies potential risks from destroying cooling pools and drawbacks from retaining cooling pools at SONGS. While the benefits of having a precautionary mechanism are identified, the process of using a cooling pool to repackage a sealed canister welded closed has never been accomplished, developed or approved by the Nuclear Regulatory Commission (NRC). Additionally, the drawbacks of maintaining a cooling pool at SONGS include delayed deconstruction and demolition of adjacent structures and loss of an alternative location for the ISFSI, among others. SCE is in the process of developing external canister repair mechanisms and overpacking methods to address canister degradation modes such as chloride induced stress corrosion cracking (CISCC), but these are only for external components. No remedies to the fuel basket, assemblies or other internal canister components are currently available once the canister is sealed. Licensing History of Spent Fuel Pools In March 2016, four years after the reactors were permanently shut down, NRC approved the SONGS revised Updated Final Safety Analysis Report for Unit 2 and Unit 3 cooling pools to reflect the reduced decay heat loads of fuel assemblies cooled and stored within. With the reactor shutdown, there would be no new spent fuel assemblies added to pools. Spent fuel has the highest decay heat load immediately after it is taken out of the reactor, with decay heat loads lowering overtime. Several exemptions to emergency planning requirements and the emergency action level were also approved by the NRC to account for the “low likelihood of any credible accident at the plant in its permanent shut down and defueled condition” in June 2015.1 In November 2017, the NRC approved exemptions to allow SONGS to switch the Permanently Defueled Emergency Plan to an Independent Spent Fuel Storage Installation (ISFSI)-Only Emergency Plan, and make the emergency action level ISFSI-only in 2015. Additional amendments to technical specifications and operating licenses of Units 2 and 3 will go into effect when all of the spent fuel assemblies are

1 Katanic, J.F. March 18 2019. NRC Letter to Doug Bauder, Subject: San Onofre Nuclear Generating Station- NRC Inspection Report 05000206/2019-001,05000361/2019-001, AND 05000362/2019-001. US NRC Region IV. P. 3, Executive Summary. www.nrc.gov/docs/ML1907/ML19071A349.pdf

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transferred from cooling pools and into dry storage at the onsite Holtec ISFSI.2 None of these amendments or exemptions explicitly require the removal or deconstruction of spent fuel pools. Current Operation of Spent Fuel Pools The March 2019 NRC inspection determined that SCE was “safely storing spent fuel in wet storage”. Specifically, there are adequate detection systems onsite and sufficient measures in place to prevent reduced spent fuel pool coolant under normal and accident conditions, keeping temperatures between 50 and 160ºF. SCE is also able to maintain standards on cooling pool water purity, radionuclide concentration, boron concentration and water levels (>23 feet between fuel bundle top and pool surface), among other requirements.3 Previous Switch to a Spent Fuel Pool Island Cooling System In 2015 SCE switched from sourcing cooling water from an open ocean once-through cooling (OTC) system to an onshore Spent Fuel Pool Island (SFPI). The SFPI is “smaller, simpler and more localized (to the spent fuel areas) than the [previous] once-through cooling system”. Two SFPI’s, one for each unit, were permitted for a term of 5 years in line with the expected completion date of fuel transfer to dry storage (December 2020). Installation occurred in August 2015. The OTC system was originally used to cool both reactors and spent fuel pools, intaking and discharging roughly 2.4 billion gallons of water each day. Once the reactors were permanently shut down, the maximum daily water intake was reduced by 96%, to 98 million gallons per day (MGD). While impacts were greatly reduced compared to the original volume of water brought in and released through OTC systems, 98 MGD can still cause severe harm to local marine life by entraining plankton during intake and increasing water temperatures and turbidity during discharge. The California Coastal Commission (CCC) notes in a staff report that the SFPI would “eliminate the need for once-through cooling water”, requiring a maximum of roughly 48 MGD to dilute other SONGS waste streams. Additionally, the closed-loop system would avoid the need to discharge cooling waters back into the marine environment.4 Instead of relying on OTC intake water, the SFPI uses a closed-loop water circulation system, adding a secondary loop that contains two 200-ton chillers to dissipate heat. This system is said to provide twice the necessary cooling capacity.5 The primary loop was largely unchanged from the original system, besides the installation of a new heat exchanger, additional piping and water circulation pumps. While this system circulates water internally, water is still lost due to evaporation from spent fuel heat loads. The addition of roughly 900 gallons per week must be added from municipal water sources to keep necessary water levels. Hazards to the SFPI Due to the distance from the shoreline (475 feet) and elevation (32 feet MLLW), the SFPI is not expected to be subject to coastal hazards such as wave runup and erosion. Additionally, “[t]he existing seawall/bulkhead in front of SONGS Units 2 and 3 is thus not necessary to protect the SFPI project from

2 Katanic, J.F. March 18 2019. NRC Letter to Doug Bauder, Subject: San Onofre Nuclear Generating Station- NRC Inspection Report 05000206/2019-001,05000361/2019-001, AND 05000362/2019-001. US NRC Region IV. P. 3, Executive Summary. www.nrc.gov/docs/ML1907/ML19071A349.pdf 3 Katanic, J.F. March 18 2019. NRC Letter to Doug Bauder, Subject: San Onofre Nuclear Generating Station- NRC Inspection Report 05000206/2019-001,05000361/2019-001, AND 05000362/2019-001. US NRC Region IV. P. 3, Executive Summary. www.nrc.gov/docs/ML1907/ML19071A349.pdf 4 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 5 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf

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credible tsunami hazards, but does provide a degree of additional protection while it is in place.”6 However, corrosion could become an issue, as rust prevention efforts require frequent use of rust inhibitors to ensure proper maintenance of the secondary SFPI loop. There is also 100 feet of stainless-steel piping used to connect spent fuel pools to chillers, though 50 feet of this piping is located inside spent fuel buildings.7 Corrosion risk to chillers is not addressed or identified as a concern in CCC staff reports. The largest hazard identified is ground acceleration caused by a large earthquake: “the primary seismic hazard at the project site is presented by ground shaking during a large earthquake centered off-site.”8 There are several faults in close proximity to SONGS, including the Newport-Inglewood-Rose Canyon Fault (8 km away), Elsinore Fault (38 km away), San Jacinto Fault (73 km away) and the San Andreas Fault (93 km away). The Cristianitos Fault runs under the San Onofre property and there are several additional fault zones located offshore. NRC analyses determined that the Newport-Inglewood-Rose Canyon Fault system poses the greatest ground shaking risk to SONGS. A 7.0 magnitude earthquake at the closest area of this fault (8 km from SONGS) could cause peak ground acceleration of .31g. To provide a conservative estimate, NRC required a design basis peak ground acceleration of 0.67.

Table 1. Probabilistic peak ground accelerations (PGA) and spectral accelerations (SA) for San Onofre determined by U.S. Geological Survey (2015) and California Geological Survey (2008) modeling and a GeoPentech study (2010) commissioned by SCE.

10% in 50 yr (g) 2% in 50 yr (g)

(475-yr return period) (2475-yr return period)

USGS9 CGS10 GeoPentech11 USGS12 CGS13 GeoPentech14

PGA 0.20-0.25 0.245 0.227 0.40-0.50 0.505 0.477

0.2 sec SA 0.50-0.60 0.564 0.53 1.0-1.2 1.113 1.111

1.0 sec SA 0.15-0.20 0.2 0.261 0.30-0.40 0.377 0.501 SFPI equipment was designed to meet 2013 CA Building Code and American Society of Civil Engineers (ASCE) 7 seismic standards, yet CCC staff remained concerned about the potential damage to this system, as it could potentially “result in the disruption or complete shutdown of the spent fuel pool cooling system”. The concern of radiological risk was outside of CCC jurisdiction, but ensuring that “new

6 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 7 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 8 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 9 U. S. Geological Survey. 2015. Seismic Hazards Science Center, Custom Hazard Maps tool: http://geohazards.usgs.gov/hazards/apps/cmaps, results synthesized by CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 10 California Geological Survey. 2008. Probabilistic Seismic Hazards Ground Motion Interpolator: http://www.quake.ca.gov/gmaps/PSHA/psha_interpolator.html, results synthesized by CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 11 GeoPentech. 2010. San Onofre Nuclear Generating Station Seismic Hazard Assessment Program 2010 Probabilistic Seismic Hazard Analysis Report, prepared for Southern California Edison, Dec 2010. Results synthesized by CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 12 U. S. Geological Survey. 2015. Seismic Hazards Science Center, Custom Hazard Maps tool: http://geohazards.usgs.gov/hazards/apps/cmaps, results synthesized by CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 13 California Geological Survey. 2008. Probabilistic Seismic Hazards Ground Motion Interpolator: http://www.quake.ca.gov/gmaps/PSHA/psha_interpolator.html, results synthesized by CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 14 GeoPentech. 2010. San Onofre Nuclear Generating Station Seismic Hazard Assessment Program 2010 Probabilistic Seismic Hazard Analysis Report, prepared for Southern California Edison, Dec 2010. Results synthesized by CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf

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development assure stability and structural integrity, and minimize risks to life and property, in areas of high geologic hazards” is a requirement of the Coastal Act. This allowed CCC to impose Special Condition One on SCE’s Coastal Development Permit, requiring SCE to submit an Inspection and Maintenance Plan for the SPFI system, including details on the type and frequency of inspections and methods to maintain all components including chillers, piping, pluming, pumps, and heat exchangers. In addition to thorough inspection and maintenance, SONGS agreed to keep replacement parts onsite for immediate repairs, and maintain the fourth chiller as a backup if one gets damaged (only three chillers are needed to maintain necessary temperatures of both pools).15 Decommissioning Spent Fuel Pools The International Atomic Energy Association (IAEA) provides four possible approaches to decommissioning spent fuel pools. These include (1) “[d]emolish entire structure to unrestricted release level”, which is the current plan at SONGS (2) “[r]etain the pool structure and form a safe enclosure by providing a waterproof cover of concrete… to ensure dry conditions”, (3) “[r]educe contamination to as low as economically possible and to backfill the enclosure with inert material such as sand”, or (4) “[d]econtaminate to a safe level for limited personnel access to and reuse the cavity as a dry interim waste store”. To note, IAEA states that “[a] strategy of doing nothing is not considered acceptable, and a strategy of retrieving all removable waste but retaining the pool full of water with residual contamination is not encouraged either. The risks associated with contamination leaking to the environment will be increased in the long term, until the pool is drained.” There is a notable concern about the level of radiologically contaminated sludge and sediment that accrues at the bottom of the pool, developed mainly as a result of corrosion.16 A report by IAEA also highlights the vast risks associated with keeping spent fuel in aging spent fuel pools, citing multiple instances of hairline cracks causing leaks of radiologically contaminated water into groundwater or the natural landscapes around nuclear plants. Listed nuclear facilities with leaking incidents associated with aging and deteriorating spent fuel pools in the United States include Indian Point and Dresden.17 Information in this report continue to validate the importance of removing spent fuel from aging cooling pools and into passive, dry storage systems. There are options for reuse of cooling pool infrastructure, such as a laboratory or alternative storage site.18 Additionally, IAEA notes that if there are adjacent dry waste storage facilities, immediately removing the cooling pool may not be the best strategy, but additional information was not provided.

[T]here are numerous situations where pools are now ready for total dismantling, and many such projects have been completed. However, the sites remain licensed areas if adjacent reactor safe enclosure structures or long term interim dry waste storage facilities are not dismantled and remain under care and maintenance. In such instances, immediate demolition of the pool may not represent the best strategy for the site.19

As such, retaining a spent fuel pool after removal would require extensive decontamination of the pool facility, but without complete deconstruction, any potential radiological contamination of soil beneath the pool would remain.

15 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 16 IAEA. 2015. Decommissioning of Pools in Nuclear Facilities: https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1697_web.pdf 17 IAEA. 2015. Decommissioning of Pools in Nuclear Facilities: https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1697_web.pdf 18 IAEA. 2011. Redevelopment and Reuse of Nuclear Facilities and Sites: Case Histories and Lessons Learned: https://www.iaea.org/publications/8305/redevelopment-and-reuse-of-nuclear-facilities-and-sites-case-histories-and-lessons-learned 19 IAEA. 2015. Decommissioning of Pools in Nuclear Facilities: https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1697_web.pdf

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Potential for Keeping a Spent Fuel Pool at SONGS To provide a mechanism for repackaging loaded spent fuel canisters, such as in the event of a loss of canister integrity or concerns about the safety of contained spent fuel assemblies, many residents around San Onofre are requesting the retention of a cooling pool onsite. Cooling pools are used for cooling spent fuel assemblies, storing spent fuel assemblies and loading spent fuel assemblies into dry storage canisters. Though previously determined to be not possible,20 SCE has since confirmed that it is possible to place a loaded and sealed canister back into a cooling pool to reopen and remove previously loaded spent fuel assemblies.21 To date, this is the only mechanism identified as an option to access assemblies and repackage spent fuel once loaded into sealed canister-based casks such as the Holtec MPC-37. SCE representatives warn that the exact protocol is not yet established or approved by the NRC, and that this process would likely pose significant hazards to workers including risk of increased radiation dose.22 The drawbacks associated with retaining a spent fuel pool at SONGS are more easily identified than benefits, simply due to the straightforward nature and established processes in place. The true risk from reduced canister integrity or benefit of being able to repackage waste is dependent on the hazard posed. Additional information from Holtec and SCE should be requested to understand the true hazards and risks associated with spent fuel storage. Benefits of Keeping a Spent Fuel Pool Onsite The potential benefits of retaining a spent fuel pool onsite at SONGS include (1) enhanced safety in the event that a canister loses structural integrity and/or ability to safely store fuel assemblies, (2) enhanced ability to ensure that waste remains transportable and (3) helping to appease community concerns. While there is ample evidence that dry storage of spent nuclear fuel is safer than the storage of spent nuclear fuel in cooling pools, there are still concerns about potential degradation modes of canister-based systems, especially in corrosion-prone environments.23 One of these degradation modes is chloride induced stress corrosion cracking (CISCC), in which a susceptible metal reacts with salt and water in an area of tensile stress. While SCE has taken precautions to reduce the potential for CISCC by peening canisters to reduce the presence of tensile stress and using a highly corrosion resistant metal (316L instead of 304, 316 or 304L), the likelihood of CISCC is low but possible. A compounding concern is that if CISCC occurs on a canister at SONGS, the ability to withstand a large earthquake (such as the highest risk magnitude 7.0 on the Rose-Canyon-Inglewood Fault) is no longer assured,24 and the ability to meet NRC requirements to safely transport canisters offsite25 may no longer be met. As of 2016 there were over 2,000 canisters loaded with spent fuel in the United States, representing 91 percent of dry storage casks in the nation.26 To date, there has been no publicly-stated incidents of

20 SCE. 2018. Regular Meeting on SONGS Decommissioning Plan Update & Used Fuel Transfer Update at the March 22 2018 Community Engagement Panel Meeting: www.songscommunity.com/community-engagement/meetings/community-engagement-panel-meeting 21 SCE. 2019. Defense In Depth Presentation at the August 22 2019 Community Engagement Panel Meeting: www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/20197/082219_DryCaskStorageDefenseInDepth.pdf 22 Information provided by SCE representatives Ron Pontes and Jerry Stephenson on August 22 2019 during an in-person meeting. 23 See “Self-Assigned Surfrider Foundation Question (2)” submitted to Congressman Levin’s SONGS Task Force in August 2019. 24 NRC. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System, Rev. 3. USNRC Docket # 72-1040 Holtec Project 5021 Holtec Report # HI-2115090 www.nrc.gov/docs/ML1619/ML16193A339.pdf 25 See 10 CFR §§ 1–171. Available here: https://www.nrc.gov/reading-rm/doc-collections/cfr/ 26 Jones, R.H. 2016. Dry Storage Cask Inventory Assessment: Fuel Cycle Research and Development. Prepared for U.S. Department of Energy Nuclear Fuels Storage and Transportation Planning Project: www.energy.gov/sites/prod/files/2017/03/f34/Dry%20Cask%20Assessment%2C%20Rev%202_0.pdf

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CISCC on dry storage canisters or other degradation method that would necessitate the potential repackaging of loaded fuel. However, unforeseen issues could still occur. For instance, in 2018, SCE and their Holtec contractors failed to thoroughly inspect the first four Holtec canisters before loading with spent fuel, resulting in the use of canisters with faulty shim pins. The canisters had already been loaded, sealed and downloaded into the ISFSI at the time that this issue was realized. Fortunately, subsequent analyses determined that the faulty shim pins posed no safety hazard to the spent fuel for the foreseeable future. While thorough inspections, increased oversight and enhanced training reduce the potential of unexpected incidents, unforeseen issues could still occur, and a method to repackage waste could potentially provide additional safety precautions and assurance that waste remains packaged in canisters that meet offsite transportation requirements. However, the safety risk of handling and reopening a faulty canister may outweigh the safety risk of repackaging. This analysis would need to occur on a case by case basis. SCE is in the process of developing external canister repair mechanisms by robot weld repair to address potential CISCC in the future, but this is only for external components. This mechanism could be mounted on mobile robotics, but specifics are still in development by SCE and the Electrical Power Research Institute.27 No remedies to the fuel basket, assemblies or other internal canister components are currently available or in development once the canister is sealed. While SCE representatives do not see repairs to internal canister components as a potential need,28 it is dependent upon the risk from and potential for unforeseen issues. Drawbacks of Keeping a Spent Fuel Pool Onsite The notable drawbacks associated with keeping a spent fuel pool onsite include (1) delayed deconstruction and demolition of other plant infrastructure, (2) delayed radiological decontamination of potentially contaminated soils (3) loss of an alternative location for the ISFSI and (4) potential for increased worker hazards including radiation dose concerns. SCE representatives state that each cooling pool is physically attached to the radiological waste containment building, even down to the foundation. Therefore, keeping a spent fuel pool would prevent the ability to deconstruct and demolish much of the large infrastructure at SONGS.29 As such, the previously completed and approved Final Environmental Impact Report (FEIR) for the demolition and deconstruction of SONGS may no longer be applicable, causing the need for a new or supplemental EIR. Additionally, keeping SONGS infrastructure onsite delays the transformation of the site back to a natural coastline, and would prevent the ability to conduct radiological decontamination of the environment around SONGS facilities, including areas underneath spent fuel pools. In the event that waste is unable to be transported offsite in the short to mid-term (2035 to 2050) or coastal hazards become too severe for the ISFSI to remain safely operating in its current location, SCE representatives have recommended an alternative ISFSI location closer to the I-5 freeway, where the cooling pools currently reside.30 This area is farther from the coastline and at a higher elevation providing a greater distance between the base of the ISFSI and the groundwater table. To date, this area has not been permitted for use as an alternative spent fuel storage area by NRC, CCC or the landowner,

27 SCE. 2019. Defense In Depth Presentation at the August 22 2019 Community Engagement Panel Meeting: www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/20197/082219_DryCaskStorageDefenseInDepth.pdf 28 Information provided by SCE representatives Ron Pontes and Jerry Stephenson on August 22 2019 during an in-person meeting. 29 Information provided by SCE representatives Ron Pontes and Jerry Stephenson on August 22 2019 during an in-person meeting. 30 Information provided by SCE representatives Ron Pontes and Jerry Stephenson on August 22 2019 during an in-person meeting.

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Marine Corps Base Camp Pendleton. It is recommended that SCE and the Task Force conduct more research about the potential for this area to be a backup location in the event that an offsite interim or permanent location for spent fuel does not become available. Lastly, the mechanism of loading a sealed canister that has been welded closed back into a cooling pool to reopen and extract previously loaded fuel assemblies has never been conducted or approved by the NRC. SCE warns that this system would not be preferred, as it could be hazardous, especially to SCE employees regarding radiological exposure.31 Without additional analyses on this repackaging method and understanding of the potential hazards and associated impacts from damaged canisters or assemblies, it is unclear if reloading and opening a canister in a spent fuel pool would cause a greater hazard than leaving the waste in potentially damaged canisters. Permitting Necessary to Keep a Spent Fuel Pool Keeping the spent fuel pool island operational would require additional maintenance and permitting to ensure that it remains structurally sound. With respect to additional permitting, at minimum SCE would need to extend their CDP for the SFPI in addition to developing an NRC approved protocol for using a cooling pool to repackage waste. Extending the CDP may require the completion of a sea level rise vulnerability assessment, development of an extended inspection and maintenance plan, decontamination the cooling pool and mechanisms to maintain all components of a SFPI, among other steps. As stated by the CCC:

“If SCE desires to retain the SFPI cooling system beyond the proposed project term, it must seek new authorization from the Commission (e.g., CDP extension or amendment). Any extension or renewal of the CDP would include a re-evaluation of the SFPI system’s ability to meet Coastal Act standards for stability

and structural integrity over the period of the proposed extension.”32 Alternative Option: The Nesting Approach As an alternative, SCE has mentioned the use of a nesting approach to address canister integrity concerns, placing damaged or faulty canisters in an overpack or slightly larger canister.33 SCE identified this mechanism as a tool to continue safe storage and even eventual offsite transportation if the structural integrity of a canister is reduced. However, technical details of this system have not yet been developed or approved by the NRC. This method would also not provide a full-repackaging option as the internal canister would remain sealed. As an example, canister #30 remained safely stored in a Hi-TRAC transfer cask at SONGS for over 11 months while the NRC completed a special inspection after the near-drop of a canister in August 2018. The cask had to be seismically restrained and contained in the fuel loading building.34 It is not clear if larger canisters used for a nesting approach would be transfer casks or a different container design; or how these overpack and nested canisters would be stored if the fuel loading building is demolished, as the Vertical Ventilated Module’s in the Holtec UMAX already provide a snug fit to single canisters.35 Additional information should be requested from SCE on this potential alternative.

31 Information provided by SCE representatives Ron Pontes and Jerry Stephenson on August 22 2019 during an in-person meeting. 32 CCC. August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 33 SCE. 2019. Defense In Depth Presentation at the August 22 2019 Community Engagement Panel Meeting: www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/20197/082219_DryCaskStorageDefenseInDepth.pdf 34 SCE. 2019. Defense In Depth Presentation at the August 22 2019 Community Engagement Panel Meeting: www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/20197/082219_DryCaskStorageDefenseInDepth.pdf 35 NRC. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System, Rev. 3. USNRC Docket # 72-1040 Holtec Project 5021 Holtec Report # HI-2115090 www.nrc.gov/docs/ML1619/ML16193A339.pdf

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Conclusion The retention of a cooling pool for the duration that spent fuel remains onsite could provide important safety precautions and offsite transportation assurance if a system is developed to safely reopen and repackage sealed canisters, but keeping this infrastructure onsite is not without potential drawbacks. This method is not yet a validated technique, would delay the demolition of other largescale infrastructure, would delay the decontamination of areas below current developments, and would block the use of a potential alternative ISFSI site; pending on the alternative site’s ability to be approved and constructed. However, as the only stated onsite option for repackaging or repair, it should be considered and vetted at least until an onsite repair mechanism is developed, approved and readily deployable onsite. This could require a temporary delay of deconstruction and demolition activities at the recently deactivated SONGS but it is not expected to negate the FEIR or cause the loss of an alternative ISFSI site in the future. The timeline for the release and approval of an onsite canister repair mechanism has not been released by SCE. Overall, the true health, environmental and financial risk from reduced canister integrity or benefit of being able to repackage waste is dependent on the hazard posed, and could be extremely notable if canister degradation were to result in a significant increase in risk of radiological contamination of surrounding environments. Additional information from Holtec and SCE should be requested to understand the true hazards and risks associated with spent fuel storage.

Self-Assigned Surfrider Foundation Question (4) What are potential on-site risks that could warrant readily deployable on-site contingency plans/assets?

Research conducted by Katie Day, Staff Scientist, Surfrider Foundation, for the Technical Advisory

Committee of Congressman Mike Levin’s, CA-49, SONGS Task Force. Summary Potential onsite risks that could warrant readily deployable contingency plans were identified by reviewing relevant local, state and federal analyses including but not limited to NRC Final Safety Evaluation Reports, California Coastal Commission staff reports, and Southern California Edison (SCE) materials. SCE must be trained and equipped to handle onsite risks, as stated by the canister manufacturer, Holtec:

In the event of an extreme environmental condition, the appropriate procedural guidance to respond to the situation must be available and ready for implementation at the nuclear plant. As a minimum, the procedures shall address establishing emergency action levels, implementation of emergency action program, establishment of personnel exclusions zones, monitoring of radiological conditions, actions to mitigate or prevent the release of radioactive materials, recovery planning and execution, and reporting to the appropriate regulatory agencies, as required.1

I. Corrosion and Degradation of ISFSI Components Due to the immediate coastal location and subterranean design of the San Onofre Nuclear Generating Station (SONGS) Holtec Independent Spent Fuel Storage Installation (ISFSI), the proximity of this structure to both seawater and groundwater is concerning. The base of the ISFSI sits 8.5 feet above the ground water table at mean lower low water level (MLLW),2 yet at mean higher high, the ground water table could be notably higher. Over the next 50 years, coastal hazards, including exacerbated storms, coastal erosion, sea level rise, groundwater level rise and seawater intrusion into groundwater aquifers could cause the Holtec ISFSI to be directly exposed to seawater and/or freshwater. Methods of potential corrosion or ISFSI degradation:

• Water inundation (see Section V.)

• Reduced structural integrity of the concrete “monolith” due to: o Corrosion induced spalling from corrosion of uncoated rebar in reinforced concrete3 o Groundwater at MLLW sits 8.5 feet below SFP,4 the current groundwater level at mean

higher high water level (MHHW) is unclear. Groundwater tables impacted by future sea level rise and potential seawater intrusion could be even higher

• Corrosion of exposed carbon steel of the CEC divider shell5 after coating is scratched during canister downloading

1 Holtec International. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System. NRC Docket # 72-1040: https://www.nrc.gov/docs/ML1619/ML16193A339.pdf 2 See US NRC email to Tom Palmisano, dated May 22, 2017. Subject: SAN ONOFRE NUCLEAR GENERATING STATION – NRC INSPECTION REPORT 05000206/2016004, 05000361/2016004, 05000362/2016004, AND 07200041/2016002 3 See Self-Assigned Surfrider Foundation Question (2) “What are potential impacts on the ISFSI and canisters if directly exposed to saltwater or groundwater?” 4 See US NRC email to Tom Palmisano, dated May 22, 2017. Subject: SAN ONOFRE NUCLEAR GENERATING STATION – NRC INSPECTION REPORT 05000206/2016004, 05000361/2016004, 05000362/2016004, AND 07200041/2016002 5 Holtec International. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System. NRC Docket # 72-1040: https://www.nrc.gov/docs/ML1619/ML16193A339.pdf

• Chloride induced stress corrosion cracking (CISCC) on the MPC6 o Loss of helium from through-wall cracks o Water inundation into the canister through through-wall cracks o Potentially reduced ability for canisters with CISCC to safely handle earthquakes

• General corrosion of the MPC due to scratching of the chrome-oxide layer during downloading

• General corrosion of Spent Fuel Pool Island components including steel piping, secondary loop components and chillers7

• Coastal erosion- Bluffs are a mix of erodible terrace deposits and San Mateo Formation sandstone/ bedrock with long term retreat estimated at 6-20 inches per year at unprotected slopes.8 Long term erosion could increase exposure of ISFSI to seawater.

• Debris blocking air vents and causing spikes in canister temperatures9

II. Mishandling or Inadequate Maintenance of Canisters or Equipment Methods of mishandling during normal and seismic conditions:

• Accidental drops of canisters or other equipment during ISFSI loading and subsequent damage to fuel assemblies10

• Accidental drops or spills of onsite chemicals or liquids11

• Failure to identify or clear blocked air vents12

• Corrosion of cooling equipment such as secondary loop components or chillers13

• Canisters not seismically restrained during transfer and downloading

• Corrosion of transfer equipment including Vertical Cask Transporter and relevant components III. Wildfire The dry landscape of Camp Pendleton is prone to wildfires from training operations and car accidents, among others. Additionally, SONGS is located next to the CA State Park with fire rings to support camp fires. There is also the potential for onsite fires due to potential mishandling of equipment or equipment malfunctions, especially during the demolition and deconstruction phase of decommissioning. The Holtec UMAX ISFSI warns that a fire could increase the temperature of the metal in the VVM and Closure Lid.14 IV. Earthquakes The ISFSI is rated to withstand a design-based earthquake resulting in 0.67 ground acceleration, which is twice the highest risk ground acceleration projected to occur from a magnitude 7.0 earthquake on the Newport Inglewood Rose Canyon Fault, determined to cause the greatest ground shaking at SONGS.15 While canisters and the ISFSI are designed to handle earthquakes, a mechanism to immediately inspect

6 Holtec International. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System. NRC Docket # 72-1040: https://www.nrc.gov/docs/ML1619/ML16193A339.pdf 7 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 8 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 9 Holtec International. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System. NRC Docket # 72-1040: https://www.nrc.gov/docs/ML1619/ML16193A339.pdf 10 See https://www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/201810/Non-proprietary%20SCE%20Summary%20of%20Hypothetical%20MPC-37%20Drop%2011-19-18.pdf 11 See https://www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/201810/Non-proprietary%20SCE%20Summary%20of%20Hypothetical%20MPC-37%20Drop%2011-19-18.pdf 12 See https://www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/201810/Non-proprietary%20SCE%20Summary%20of%20Hypothetical%20MPC-37%20Drop%2011-19-18.pdf 13 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 14 See https://www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/201810/Non-proprietary%20SCE%20Summary%20of%20Hypothetical%20MPC-37%20Drop%2011-19-18.pdf 15 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf

the canisters and ISFSI integrity after the fact should be deployed. If canisters or ISFSI components are impaired, a readily onsite mechanism for immediate repair is recommended. It is unclear if seismic ratings apply to degraded canisters or structures. Faults in close proximity to SONGS:16

• Active Faults o 8 km from Newport-Inglewood-Rose Canyon Fault o 38 km from Elsinore Fault o 73 km from San Jacinto Fault o 93 km from San Andreas Fault

• Inactive Fault o Cristianitos Fault runs under the property

• Offshore Faults o Coronado Bank Fault Zone o San Diego Trough Fault Zone o Thirty-Mile Bank Fault o Oceanside Thrust o Wilmington Blind Thrust Fault17

V. ISFSI Water and Debris Inundation SCE should develop a readily deployable onsite mechanism and protocol for removing water and debris from Vertical Ventilated Modules (VVM) to ensure that canister surfaces remain dry and free of debris to prevent corrosion and maintain safe cooling capabilities. Methods of potential water inundation:

• Rainwater o The ISFSI pad is designed to direct rainwater and any potential spilled liquids away from

VVM air vents to prevent entry into the VVM and direct contact with canisters; however, large rain events may be able to reach the air vents and enter the VVM. The base of the VVM’s are sealed, so the only way to remove infiltrated water is to physically pump the water out.18 Contained water could have higher salinity due to potential sea spray, so a method to not only remove water but ensure that canister surfaces are dry and free of salt would help reduce the potential for CISCC.

• Runup from tsunamis paired with sea level rise and king tides o The highest potential tsunami runup is estimated at 23 feet under current sea levels.

The seawall is currently 31 feet MLLW19 and is expected to provide sufficient protection from direct runup while properly maintained; however, it is recommended to assess the potential for wave runup elsewhere on site to reach the ISFSI by flowing from alternate locations, as some areas on the SONGS property are as low as 19 feet MLLW.20 It is also recommended to consider exacerbated run-up heights when paired with sea level rise and king tides.

16 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 17 Wolfe, F.D., Shaw, J.H., Plesch, A., Ponti, D.J., Dolan, J.F., & Legg, M.R. 2019. The Wilmington Blind Thrust Fault: An Active Concealed Earthquake Source beneath Los Angeles, California, Bulletin of the Seismological Society of America. https://pubs.geoscienceworld.org/ssa/bssa/article-abstract/572981/the-wilmington-blind-thrust-fault-an-active?redirectedFrom=PDF 18 Holtec International. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System. NRC Docket # 72-1040: https://www.nrc.gov/docs/ML1619/ML16193A339.pdf 19 CCC August 11 2015 Staff Report: https://documents.coastal.ca.gov/reports/2015/8/th15a-8-2015.pdf 20 CCC August 22 2019 Staff Report: https://www.coastal.ca.gov/meetings/agenda/#/2019/9

o Tsunami-induced wave runup under current sea levels ▪ 8.5-22 ft MLLW onshore runup expected from an 9.0-9.5 magnitude earthquake

in Eastern Aleutian Islands21 ▪ 10-21.5 ft MLLW onshore runup expected from a 7.5 magnitude earthquake on

the offshore blind thrust fault22 ▪ 20-23 ft MLLW onshore runup from the upper bound tsunami (California

Emergency Management Agency 2009)23 VI. Attacks and Explosions Methods of potential degradation caused by attacks and nearby explosions:

• Increased pressure on the VVM caused by an explosion event near the VVM24

• Tornado-induced missile strike of the Closure-Lid25

• Loss of VVM structural ability to safely handle weight load of the Vertical Cask Transporter and therefore loss of ability to safely retrieve canisters from the UMAX26

21 Kirby, J.T. 2013. SONGS Calculations for Probable Maximum Tsunami, prepared for Southern California Edison Company 22 Kirby, J.T. 2013. SONGS Calculations for Probable Maximum Tsunami, prepared for Southern California Edison Company 23 See www.conservation.ca.gov/cgs/Documents/Tsunami/Maps/Tsunami_Inundation_SanOnofreBluff_Quad_SanDiego.pdf 24 Holtec International. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System. NRC Docket # 72-1040: https://www.nrc.gov/docs/ML1619/ML16193A339.pdf 25 Holtec International. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System. NRC Docket # 72-1040: https://www.nrc.gov/docs/ML1619/ML16193A339.pdf 26 Holtec International. 2016. Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System. NRC Docket # 72-1040: https://www.nrc.gov/docs/ML1619/ML16193A339.pdf