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Last week, the Surfrider Foundation’s Legal Fellow, Amy Foo, presented at the California State Lands Commission (SLC) hearing in Oceanside and provided comments on the adoption of the Final Environmental Impact Report and lease agreement with Southern California Edison (SCE) for the decommissioning of San Onofre Nuclear Generating Station (SONGS). Decommissioning activities include the decontamination and dismantlement of major onshore above and below ground structures, removal of primary and ancillary intake structures for Units 2 & 3 and removal of navigational and environmental monitoring buoys.
SLC is the state regulatory agency that manages hundreds of thousands of acres of public trust lands and resources. One of its primary responsibilities includes issuing leases for use of these lands and resources and to provide for their protection now and for future generations. On behalf of Surfrider, Amy raised a number of ecological, recreational and human health concerns related to the decommissioning activities, several of which were accepted and addressed in the SLC’s lease agreement with SCE.
Surfrider commented on the EIR and lease, with several points of contention. Our main asks included:
Decline to approve dismantling of the cooling system. Surfrider is calling for there to be a readily available onsite method of transferring waste or fixing a canister should a canister’s integrity be compromised, such as retaining a cooling pool on site, developing a hot cell, or other method pre-approved by the canister manufacturer and the NRC. Unfortunately, this ask was dismissed by SLC and SCE as outside the scope of the project and unnecessary.
Evaluate Alternative Spent Fuel Storage Locations. Surfrider recommends that a representative from SLC and/or California Coastal Commission be appointed to engage in spent fuel relocation efforts, including but not limited to the Congressman Mike Levin SONGS Task Force, which is currently in formation. This recommendation was not incorporated into the lease agreement but is currently under consideration and likely to be fulfilled.
Evaluate and Monitor Sea Level Rise. As a result of Surfrider’s request, SLC included special lease provisions that ensure annual sea level rise vulnerability assessments, combined with multiple storm and tide scenarios, are conducted, including an extreme sea level rise scenario. In addition, groundwater rise will be monitored due to Surfrider’s expressed concerns that the independent spent nuclear fuel storage installation (ISFSI) may be subject to flooding under future sea level rise scenarios. This is a key win and while our ask for a thorough extreme sea level rise projection analysis with data on potential impacts to the ISFSI to be analyzed was not included, the annual reporting and monitoring report will help gauge ISFSI safety from coastal hazards.
Increase Ocean Monitoring and Publicize Results. SCE agreed to include three additional ocean and shoreline monitoring locations at key nearby recreational sites (two north of SONGS and one to the south) at Surfrider’s request and that data will be made public and published within 30 days of completion in an interactive map on the SONGS community forum at www.songscommunity.com. In addition, the public will be notified at least 48 hours in advance of any batch releases of effluent.
While we appreciate SCE’s intention to return this segment of Coastal California to a natural shoreline, we remain concerned that a readily available onsite method of transferring waste or fixing a canister, should a canister’s integrity be compromised, is a gaping oversight. We do, however, appreciate SCE and SLC’s efforts to include our additional sea level rise assessment and ocean monitoring provisions. Overall, we feel these will be helpful safety and accountability measures.