Coastal Preservation
March 27 2019

SONGS Nuclear Update: Reef Expansion, Civil Penalties and Sea Level Rise

by Katie Day

Photo by Swan Dive Media

If you’ve been following the San Onofre nuclear power plant decommissioning project, you know that it’s been a bit of a hot mess, literally. From an initial steam generator leak in 2013 that triggered the decommissioning of the plant, to loading spent fuel in canisters with potentially defective shim pins, to nearly dropping a loaded canister causing an official review by the Nuclear Regulatory Commission (NRC) and subsequent identification of widespread inadequacies in training and supervision, there’s been a lot going on. In addition to all of this, the plant’s majority owner and operator, Southern California Edison (SCE), was unable to meet kelp mitigation requirements, which has created the need to expand an artificial reef by more than 210 acres.

The Surfrider Foundation is strongly opposed to permanent or long-term storage of radioactive waste at the deactivated San Onofre Nuclear Generating Station (SONGS) due to its proximity to the coastline, susceptibility to geological instability and location within a densely populated area. Surfrider recognizes that the waste needs to be cooled onsite before it's moved and we demand that this is done as safely as possible, while also advocating that the waste is moved as soon as possible to a consent-based, geologically stable permanent location away from the coast.

With all these moving pieces, we thought it was time for an update.

  1. Storage of Spent Fuel and the Continued Delay of Loading

Since a whistleblower made the public aware of SCE's contractors nearly dropping a canister loaded with high level radioactive waste, or spent fuel, (learn more here), SCE has temporarily ceased the loading of canisters with spent fuel. This is significant because according to SCE’s March 1 Spent Fuel Progress Report, there are still 1,558 assemblies in cooling pools awaiting transfer into dry storage. There are 43 canisters that need to be filled (in addition to one canister that’s been filled but is currently held in the fuel loading facility until fuel downloading is approved to resume). The complete transfer process of all waste from cooling pools to dry storage was estimated to take about 1.5 years. However, due to SCE’s negligence to properly train and supervise their employees and contractors on the downloading of canisters into the open air storage facility, this process is going to take much longer. In the end, we would rather that they do this carefully and right instead of cutting corners and rushing the process.

In addition to not having redundant drop protection (an NRC violation level 2), the near drop also highlighted the issue that canisters are getting scratched during the downloading process. According to this week’s NRC Enforcement Decision Public Webinar, the canister manufacturer’s Final Safety Analysis Report (FSAR) specified that no scratching is supposed to take place, meaning the canister integrity assured by the FSAR does not apply to these previously downloaded canisters. At this point, assessments by SCE and NRC have concluded that the “minor scratches” on canisters do not cause any additional safety hazards and the canisters should maintain their integrity. However, this is not official until the FSAR is updated to allow for minor scratches. Last week, SCE started physically inspecting canisters with camera equipment to better understand the level of scratching that has occurred. SCE and Holtec (the canister manufacturer) are trying to update the FSAR to allow for "minor scratches" to the canister during downloading, and NRC is in the process of reviewing this request. SCE will not resume loading until they update the dry storage system’s FSAR, which could take some time.

  1. NRC Enforcement Decisions Regarding Level 2 and 3 Violations

NRC recently announced their “final enforcement decision” on SCE’s negligence in a webinar on March 25, which included a $116,000 civil penalty. Though this may not sound like much, this is actually double the minimum fine for that violation level. NRC pushed for this larger fine because SCE’s initial corrective actions had significant weaknesses (such as claiming certain pieces of equipment weren't classified as necessary for safety when they were, procuring equipment that was not in accordance with requirements and then having them tested by an unqualified vendor, missing contingency steps especially regarding seismic protection, not updating maintenance procedures, and more). NRC also mentioned that all of these weaknesses in the initially proposed corrective actions have since been addressed and that the new corrective actions are robust.

  1. Decommissioning Plan Gets Approved by SLC, but with Important Additions

Related but separate from the nuclear waste transfer from cooling pools into dry storage, is the actual demolition and deconstruction of the plant’s infrastructure, known broadly as “decommissioning.” Once all the waste has been moved to dry storage on the northern side of the coastal property, SCE will start the long process of dismantling the massive concrete and steel structures that previously held the nuclear reactor and all the related facilities, including operating rooms, fish conduits, and more. At this point, according to the Final EIR, the only infrastructure they plan to leave are the open ocean discharge and intake pipes, the seawall, and materials buried several feet below the surface. See Surfrider’s comment letter on the DEIR to learn more about our concerns and asks regarding this process.

Fortunately, last week the CA State Lands Commission and SCE heard many of Surfrider’s requests, and SCE committed to conduct annual sea level rise vulnerability analyses of the coastal storage facility (including consideration of the extreme sea level rise projection of H++), groundwater level monitoring, and expanded radiological sampling at coastal recreation sites, which will be published in near-real time on a publically available interactive map. Learn more here.

4.) Wheeler North Reef Expansion Project

As mitigation for the loss of kelp forest and fish biomass due to the initial construction and operation of SONGS, mainly from increased water turbidity from discharge pipes, SCE was required by the Coastal Commission to build an artificial reef that meets a range of environmental thresholds. Since the artificial reef, named Wheeler North Reef, was completed in 2008, it has met most of the absolute and relative standards, with the exception of the required standing fish stock of 28 tons, based on monitoring by the UC Santa Barbara Marine Science Institute. This means that even though the reef has been active for 10 years, SCE still has all 30 years (and counting) of mitigation requirements to meet.

SCE plans to expand the 174.4 acre-reef by another 210.6 acres, by placing 175,000 tons of quarry rock offshore of San Onofre, in an attempt to increase the habitat and therefore the standing fish stock. Surfrider is appreciative of the effort to expand a kelp forest and provide additional habitat for marine life, and submitted comments on the DEIR to request robust environmental and recreational monitoring during this project. Earlier this month, the Coastal Commission approved the reef expansion project, unfortunately without surf monitoring. Anecdotally, the initial reef construction did not have a noticeable impact on surfing waves at nearby breaks, but Surfrider would like to see more thorough and official monitoring of this important recreational and cultural resource.

5.) Need for Federal Action to Get the Waste Off the Coast

The federal government is the only entity that can truly supply a long-term solution for storage of nuclear waste offsite. Surfrider is calling for a federally-appointed permanent storage site away from the beach, with consent- based siting, environmental review and a strict timeline from the federal government to quickly and safely move nuclear waste away from the dynamic coastline.

Here is how you can ask your elected representative in Congress to help address the problem at the federal stage: Tell Congress to Get Nuclear Waste Off the Beach

Recently, Congressional Representative Mike Levin, representing California’s 49th Congressional District where SONGS is located, has pledged to start a Task Force to address the challenges at San Onofre Nuclear Generating Station.  According to his website, “Representative Levin has been a longtime advocate of long-term solutions to address the hazardous waste as well as short-term solutions regarding canister safety at San Onofre.”  While the Task Force has been announced, the participant list has not been finalized and it has yet to gather.

To learn more about Surfrider’s campaign to Get Nuclear Waste Off California’s Coast, visit our campaign page and take action. You can also attend the next SCE Community Engagement Panel public meeting taking place this Thursday, March 29, at the Laguna Hills Community Center. Click here for details.