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CEP Regular Meeting

Outlier Events and Response StrategiesThursday, May 28, 2020

5:30 - 8:30 p.m.Virtual Meeting for Social Distancing

DRAFT

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Submit comments to: nuccomm@songs.sce.com

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Agenda Topic Presenter Time

CEP and SCE welcome & opening comments• Skype – how to participate in public comment period• SONGS pandemic protocol and sewage treatment plant wastewater release

David Victor Doug Bauder

5:30 - 5:35 (5 min)

The big picture: SONGS decommissioning • Fuel transfer operations and dismantlement activities

Doug Bauder 5:35 – 5:40 (5 min)

Outlier events and response strategies – Initial comments• Overview of process and events in and out of scope

David VictorExternal stakeholdersDoug Bauder

5:40 – 5:50 (10 min)

“Radiation 101”• Radiation and contamination • Spent fuel design and operating experience

Patrick PapinRandall Granaas (SCE)

5:50 – 6:00 (10 min)6:00 – 6:05 (5 min)

Plausible event scenarios and responses - Analysis (probability/consequence), hazards, mitigations, radiation, contamination and dose to the public• Outliers, experts and perspectives• Canister degradation • Terrorism / sabotage• NRC rulemaking• San Onofre security

Tom Isaacs Mike CorradiniKevin CrowleyEd Lyman Ross Quam

6:05 – 6:10 (5 min)6:10 – 6:20 (10 min)6:20 – 6:30 (10 min)6:30 – 6:40 (10 min)6:40 – 6:45 (5 min)

Layers of emergency preparedness• On-site response capabilities• Off-site response capabilities – local, state, and federal

Kelli Gallion Donna Boston (OC)Stephen Rea (SD Co.)

6:45 – 7:05 (20 min)(7 minutes each)

Break 7:05 – 7:15 (10 min)

Public comment period (Q&A related to agenda topics and general questions & comments) 7:15 – 8:15 (60 min)

Facilitated public dialogueDan StetsonJerry Kern

8:15 - 8:30 (15 min)

SCE and CEP closing commentsDoug BauderDavid Victor

8:30 – 8:35 (5 min)

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Welcome and Opening Comments

David Victor and Doug Bauder

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Opening Comments

David Victor

• Virtual meeting– Skype format in the interest of public health and safety– Process for public comment

• Questions submitted to nuccomm@songs.sce.com in advance will be addressed first• Use online form to sign up for public comment: https://on.sce.com/cep• Dan Stetson and Jerry Kern will review and facilitate the Q&A period

• Welcome expert panelists

Radiation Outlier Scenarios Emergency Response

Mike Corradini Kelli Gallion-Sholler

Patrick Papin Kevin Crowley Donna Boston

Tom Isaacs Stephen Rea

Ed Lyman

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Opening Comments

Doug Bauder

• Continuing essential work under requirements of SONGS pandemic protocol

• Fuel transfers from wet to passive dry storage• Limited deconstruction work authorized by SCE

• Update on sewage treatment plant • Wastewater release on March 25

• More information on decommissioning in CEP newsletter on website www.songscommunity.com

The Big Picture

Doug BauderChief Nuclear Officer and

VP Decommissioning

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Safe and prompt deconstruction

Defense-in-depth for on-site storage of spent nuclear fuel

Take action in an effort to relocate spent fuel off site

The Big Picture

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• Transferring spent nuclear fuel to passive dry storage

– 9 of 73 canisters remaining to download as of today

– Continuing process improvements and lessons learned

– On pace for completion mid-summer

• Limited dismantlement work authorized by SCE continues

– Shipment of low-level waste (Unit 1 reactor pressure vessel)

– Continued waste removal (asbestos)

– Office trailers for employees during deconstruction

Decommissioning

Update

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First Quarterly Update

• Tri-fold mailed in April

• Posted onlinehttps://www.songscommunity.com/about-decommissioning/decommissioning-san-onofre-nuclear-generating-station

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Outlier Topic

• Tonight’s discussion:• Initial comments by CEP leadership and Working Group

• Basics of Radiation and Contamination - “Radiation 101”

• Experts address top outlier scenarios

• Emergency management experts address response

• Public comment

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Initial comments: the processDavid Victor• Multiple sources of community input for agenda items:

• External stakeholders (CEP comments, petition, correspondence)

• Local city managers

• Working Group

• Three in-person meetings and one via Skype

• Planning, nomination of experts and standard for choosing experts

• Expert-driven assessment

• Experts recommended by National Academies of Sciences

• Contributed to list of scenarios

• Ranked scenarios based on consequences

• Distinguished between ”fast occurring” and “slow emerging” scenarios

• Process summary and online library

• Chairman’s summary of process and documentation available on website [hyperlink]

• Tonight’s focus is on a few scenarios of greatest consequence and public interest

• Other topics covered by online library https://www.songscommunity.com/community-engagement/meetings/community-engagement-panel-meeting-20200421

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Outlier Events and Response StrategiesInitial Comments

Roger Johnson

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Outlier Events and Response StrategiesInitial Comments

Katie Day Surfrider Foundation

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Outlier Events and Response StrategiesInitial Comments

David Victor

Initial comments: ISFSI-onlyDoug Bauder

• ISFSIs are highly robust, designed with significant events in mind

• Safe and passive operation

• Compared to operating reactors, ISFSIs are low-risk• Emergency Action Levels reduced from 82 during

operations, 18 permanently defueled, to 3 at ISFSI-only

• Zero accident scenarios with offsite radiological release

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The initial listDavid Victor• Canister drop

• Corrosion and/or cracking of a canister due to chloride-induced stressed corrosion cracking (CISCC)

• Groundwater daylighting

• Postulated crack allows water to enter canister allowing hydrogen buildup and explosion

• Sea level rise

• Seismic events

• Terrorist attack

• Tsunami

• Vibration from decommissioning and dismantlement activities

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Outlier prioritization processDavid Victor

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Outlier Scenarios Agenda Topic Library Fast-Occurring EventsTerrorism

Insider sabotage

Seismic events

Tsunami

Canister drop

Nearby pipeline explosion

Aircraft impacts/jet fuel fire

Slowly Emerging EventsCanister degradation (CISCC)

Postulated undetected through-wall crack, water intrusion, hydrogen build-up, ignition

Postulated zirconium fire

Sea-level rise

Groundwater daylighting

Vibration from dismantlement activities

Postulated staffing shortage due to COVID-19

Library-only scenariosDavid VictorSea level rise (SLR)

• 2015 Coastal Development permit (reviewed annually)

• Ocean Protection Council’s most extreme scenario (2018 “H++”), does not represent a threat to the ISFSI through 2035

• SCE will revisit SLR in relation to the Holtec facility in 2035

• The bottom of the new Holtec UMAX spent fuel storage facility sits three feet above the water table

• Sea water would need to rise three feet, then penetrate three feet of reinforced concrete and a 3/4 inch stainless steel cavity enclosure container that houses the canister

• Units 2 and 3 were built below the water table and operated for nearly 30 years with no impact from the water table or sea water

https://www.songscommunity.com/search?q=sea-level+rise&s=relevance

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Library-only scenarios (cont.)David VictorGroundwater daylighting

• Ground water assessments are performed annually and provided to CA State Lands Commission

• Ground water projections through 2050 indicate that the bottom of the Holtec storage facility remains dry with approximately 6 inches margin assuming the H++ SLR scenario

https://www.songscommunity.com/search?q=sea-level+rise&s=relevance

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Library-only scenarios (cont.)

David Victor• Seismic Safety at San Onofre

• https://www.songscommunity.com/need-to-know/overview/seismic-safety-at-songs

• Dr. Neal Driscoll presented Scripps seismic research during February 16, 2017 CEP meeting

• https://www.songscommunity.com/community-engagement/meetings/regular-meeting-on-the-new-scripps-seismic-research-introduction-of-decommissioning-general-contractor

• Additional information and new studies are available• https://www.songscommunity.com/safety/seismic-safety

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Library-only scenarios (cont.)

David Victor• Tsunamis

• “Tsunami Hazard Analysis and Protection” (SCE Position Paper) - explains how spent nuclear fuel stored at the Independent Spent Fuel Storage Installation and Units 2&3 Spent Fuel Pools is protected against a potential tsunami hazard. The paper summarizes the results of the site-specific tsunami analyses that have been performed, and how protection is assured for the ISFSI and the Spent Fuel Pools.

https://www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/20182/PositionPaperTsunami.pdf

• “Independent Spent Fuel Storage Installation (ISFSI) Location” (SCE Position Paper) - provides the background and basis for SCE’s decision for the location of the ISFSI at San Onofre. A link is provided here.

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Library-only scenarios (cont.)

David Victor• Canister drop

• Discussed extensively at 2018 and 2019 CEP meetings

• Vibration from dismantlement work• Well-analyzed, far below levels that could affect ISFSI

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RADIATIONAND

CONTAMINATION

SAN ONOFRE NUCLEAR GENERATING STATIONCOMMUNITY ENGAGEMENT PANEL

MAY 28, 2020

DR. PATRICK PAPIN

DEPARTMENT OF PHYSICS

GRADUATE PROGRAM IN HOMELAND SECURITY

SAN DIEGO STATE UNIVERSITY24

TOPICS OF DISCUSSION

• Radiation

• Exposure and Contamination

• Shielding

• Dose Perspective

• What is Safe?

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RADIATION

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• Energy given off by matter in the form of rays or high-speed particles

• Ionizing radiation removes electrons from atoms, causing the atoms to become electrically charged ions

• Alpha particles

• Beta particles

• Gamma Rays

• X Rays

• Neutrons

EXPOSURE AND CONTAMINATION

• Exposure• The act or condition of being subject to radiation

• Minimizing exposure • Time, distance and shielding (all used SONGS)

• Contamination• Radioactive material present in any substance, area, or

on any surface where it is unwanted or unexpected

• Dose• Absorbed energy and potential biological effects

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SHIELDING

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Thick steel and concrete are used for dry storage at San Onofre

DOSE PERSPECTIVE

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WHAT IS SAFE ?

• Radiation annual dose limits

• Federal occupational dose limit 5000 millirem

• (Lower) SONGS worker dose limit 1500 millirem

• NRC and SONGS limits for the public 100 millirem

• Limits set to safe levels by NRC and recommended by various national and international agencies1

• At these limits there is:

• Nearly no chance of deterministic effects (e.g. hair loss)

• Minimal risk of stochastic effects (e.g. cancer)

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1 Safe levels are recommended by the National Council on Radiation Protection & Measurements and the International Commission on Radiological Protection

TO BE CONTINUED…….

QUESTIONS?

Contact Info:

ppapin@sdsu.edu

https://physics.sdsu.edu/ppapin/

https://homelandsecurity.sdsu.edu/31

Spent Fuel Design

and Operating

Experience

Randall Granaas

SCE Nuclear Fuel / ISFSI Engineer

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Solid State Spent Nuclear Fuel

• Ceramic uranium dioxide fuel pellets– Requires 5,000 degrees F to melt– Cooling since 2012– Decay heat of SONGS hottest spent fuel assembly comparable to a hair

dryer (~1500W)• Sealed within corrosion-resistant

zircaloy rods (“cladding”) and pressurized with helium

• Organized into fuel assemblies• In dry storage, assemblies are sealed

within stainless steel canisters

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Operating Reactors

vs.

SONGS Spent Fuel

• Offsite releases at Chernobyl and Fukushima due to motive force associated with an operating reactor (extreme heat and steam)

• Cesium-137 not volatile at dry storage temperatures (boiling point of ~1250° F)– SONGS fuel lacks the energy to volatilize

cesium, not directly comparable to Chernobyl and Fukushima

– No water in dry storage

• Absent a motive force, radioactive contamination on the surface of the fuel, and fuel particulate, are not very mobile

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Forced Helium Dehydrator Filter

Replacement

(Empirical Data)

• Typical replacement of filters

for FHD system

• Helium at 400° F and ~80 psig

circulated through canister for

about 24 hours

• Does not result in removal of

significant quantities of

radioactive material from the

canister, even when drying

damaged fuel

• Filters are only mildly

radioactive 35

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Outlier Events and Response StrategiesExpert Introductions

David Victor

Outliers, Experts, and

Perspectives

Tom Isaacs

SCE Experts Team Chairman, Independent Strategic Advisor for Nuclear Waste,

Lead Advisor, Blue Ribbon Commission on America’s Nuclear Future

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Criteria to Consider

• Plausibility

• Stakeholder interest

• Human judgment, not quantitative analysis

• Most experts approach in a risk-informed way

• Human induced scenarios should consider role of human error or deliberate act/terrorism

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Organizing Outliers

• Naturally occurring

• Human induced

• Fast occurring event

• Situation emerging over time

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Organizing Outliers

FAST(Occurrence)

SLOW(Emergence)

NATURAL

Seismic / Tsunami Sea Level Rise / CISCC

HUMAN Terrorism / Canister

Drop

Canister Degradation(postulated crack and water

intrusion)

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The Initial List• Canister drop

• Corrosion and/or cracking of a canister due to chloride-induced stressed corrosion cracking (CISCC)

• Groundwater daylighting

• Postulated crack allows water to enter canister allowing hydrogen buildup and explosion

• Sea level rise

• Seismic events

• Terrorist attack

• Tsunami

• Vibration from decommissioning and dismantlement activities

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Defining Scenarios

• Mechanistic: relates to theories that explain phenomena in purely physical or deterministic terms; by physical process alone

• Postulated: defined as “assume the existence of”

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Some Additional Thoughts

• One of the biggest risks is complacency

• Continuous improvement helps maintain vigilance and expectations

• Earning trust and providing compelling, clear information are key

• It’s also possible to create unhelpful dread and anxiety that can lead to bad decision making

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Scenario:Postulated-crack/Water-intrusion/H2-burn

Michael Corradini, EmeritusDistinguished Professor of Nuclear Engineering

Engr. Physics, University of Wisconsin

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Background

• This evaluation is not mechanistic (not based on any accident analysis but analyzed for CEP discussion):

– Postulated: crack allows water to enter a canister

– Postulated: combustible mixture of hydrogen (H2) and oxygen (O2) in the canister due to water intrusion and radiolysis, ignition and combustion

– This discussion does not imply that an H2 burn within a dry storage canister is a credible event

– Consulted: Profs. Art Motta (PSU) & Joe Shepherd (CIT)

• Refs: PNNL-6365, CNWRA-NRC–02–07–C–006, 2013

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Scenario: Postulated-crack/Water-intrusion/H2-burn

Postulated Scenario Events:

• Cracking of spent fuel canister

• Water ingression into canister through a crack

• Water radiolysis => H2 and O2 in the canister

• Combustible gas (H2 and O2) builds up

• Ignition and H2/O2 combustion causes pressure

increase as a challenge to canister integrity

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Scenario: Postulated-crack/Water-intrusion/H2-burn

Postulated Scenario event: Cracking of Spent Fuel canister

Through-wall crack of canister postulated to come from chloride-induced stress corrosion cracking (CISCC) in coastal environment

• AREVA and HOLTEC systems at SONGS are 316L Stainless steel (5/8” thick) specifically for coastal environment

• CISCC is a known process that develops slowly and requires specific conditions to initiate.

• Inspections are done regularly for selected sets of canisters to detect any corrosion. Should any corrosion be observed, approved/proven remediation techniques would be taken.

• The cracks produced would be likely plug by further oxidation or would be so small as to prevent the ingress of water.

• This thru-wall crack is postulated, but is highly unlikely47

Scenario: Postulated-crack/Water-intrusion/H2-burn

Postulated Scenario events: Water ingression & water radiolysis

Radiolysis of water postulated to produce a combustible mixture

• Water ingress into the canister is assumed to occur without identifying source or any actions taken to preclude event

• Rate of H2/O2 production from steam/water exposure is difficult to predict as it is a function of radioactive decay emissions, flux and absorption

• Neglects oxygen uptake by oxidation of metallic surfaces

• Time to reach a combustible mixture would take decades within the canister

• Neglects the escape of H2 through the path from which water entered.

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Scenario: Postulated-crack/Water-intrusion/H2-burn

Postulated Scenario event: H2 combustion

Postulate combustion of hydrogen-oxygen mixture causes a pressure rise to challenge canister integrity• No ignition source exists in the canister, but is assumed

• The limiting event would be a contained combustion of a flammable mixture

Given all of these conservative assumptions, analyses result in combustion pressures less than half of the design pressures for the canisters; there is no gross canister failure

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Terrorist Attacks on

Dry Storage Systems for

Spent Nuclear Fuel

Kevin D. Crowley, PhD

Retired Former Senior Board DirectorNuclear and Radiation Studies BoardNational Academies of Sciences,

Engineering, and Medicine

Dry Storage System

Vulnerability Assessments

Dry storage system vulnerability assessments have been carried out by governments, national

laboratories, nuclear industry, and independent analysts

United States

• Assessments of transportation cask sabotage (1970s-) (e.g., Luna et al., 1999)

• Assessments following 9/11 attacks to inform potential ISFSI security orders (2003-)

• Assessments to support ISFSI security rulemaking, now postponed (2012-)

International

• Germany: Assessments to address longstanding concerns about military aircraft crashes and terrorism

• Others

Assessment Topics, Objectives, and Availability

These assessments have improved understanding of potential vulnerabilities, but limited information available in public domain

• Aircraft attacks

• Ground assaults using high-energy devices & explosives

• Numerical modeling & physical experiments

• Attack sequences, system containment performance, potential radioactive material releases

• Most results “classified” or otherwise precluded from public disclosure; some publicly available information pulled back after 9/11

• National Academy of Sciences (NAS) reports (next slide) provide public summaries of some nonpublic assessments

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NAS, 2006

NAS, 2016

Reports available in library

Post-9/11 congressionally mandated review of potential vulnerabilities of dry storage systems to terrorist attacks:

• Aircraft attacks• Ground assaults with high-energy devices & explosives

Classified study with classified (NAS, 2004) and public (NAS, 2006) reports

Post-Fukushima congressionally mandated reevaluation of NAS (2004, 2006) conclusions in light of newer information:

• Classified study with public report (NAS, 2016)• Reviewed Nuclear Regulatory Commission (NRC) vulnerability

assessments to support ISFSI rulemaking• NRC assessments still in progress when review completed• NAS (2016) recommended that NRC give high priority to

completing assessments and ISFSI rulemaking

Example 1: Shaped Charges

• Shaped charge: Explosive device designed to focus blast energy; used for cutting hard materials

• Testing of shaped charge anti-tank weapon on ductile cast iron (Castor) cask (NAS, 2006)

• Bare cask breached (photo)• Cask with concrete jacket not breached

• Material releases from breach of unjacketed Castor cask containing simulated fuel elements (Lange et al., 1994)

• 3.6 g (1 g respirable) uranium particulates released in test

• Calculated inhalation doses were < 50 mSv (5 rem) at 50 m (~160’) from cask

• Note: Material releases could include gases and particulates; release quantities depend on number of damaged fuel elements and other factors

54NAS, 2006, Figure C.4

Example 2: External Impacts

• High-speed impacts on simulated overpacks for two commercially available dry storage systems (Lee et al., 2014)

• Part of effort to simulate B747 aircraft engine impacts on dry storage systems

• 110 lb high-strength steel slugs fired at simulated overpacks from 155 mm cannon

• Slugs penetrated overpacks to different depths and deformed rear steel liners by about 2”

• Test neglects some important design features of real overpacks but illustrates the robustness of dry storage systems

55Photos from Lee et al., 2014

Key Messages About Dry

Storage System Security

• Robust designs of dry storage systems help protect spent fuel from terrorist attacks

• Massive physical shielding• Multiple barriers to radioactive material releases

• No dry storage system provides complete protection against all attack types (NAS, 2006)

• Any radioactive material releases from attacks would likely be relatively small

• Jet fuel fires from aircraft attacks would likely be dispersed and short duration

• Effective dry storage security requires• Physically robust dry storage systems

• Strong facility security to isolate dry storage systems from people and vehicles

Key Physical Characteristics of SONGS Dry Storage Systems

• UMAX storage is low profile, partially underground, and protected by thick reinforced concrete pad and plugs

• NUHOMS storage modules are massive (~ 400,000 lbsloaded) with thick reinforced concrete shielding

• NUHOMS storage modules partially screened to oceanfront by UMAX ISFSI

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Photo from SCE

Closing Comments

• Difficult for terrorists to successfully attack dry storage systems if “success” defined by release of radioactive materials

• Robust facility security ESSENTIAL for isolating stored spent fuel from people & vehicles to keep security risks low (see presentation by Dr. Lyman)

• Continually assess and adjust security posture to counter newly identified threats

• Continually plan for “what can go wrong” at the ISFSI and have readily deployable countermeasures available

References

• Lang et al., 1994. Experimental Determination of UO2-Release from Spent Fuel Transport Cask after Shaped Charge Attack. INMM 35th Annual Meeting Proceedings, 408–413. Available at https://resources.inmm.org/system/files/annual_meeting_proceedings/1994/167.pdf.

• Lee et al., 2014. Impact analyses and tests of concrete overpacks of spent nuclear fuel storage casks. Nuclear Engineering and Technology 46(1), 73-80. Available at https://www.sciencedirect.com/science/article/pii/S1738573315300929.

• Luna et al., 1999. Projected Source Terms for Potential Sabotage Events Related to Spent Fuel Shipments. SAND 99-0963. Available at https://www.nrc.gov/docs/ML0106/ML010650451.pdf.

• NAS, 2004. Safety and Security of Commercial Spent Nuclear Fuel Storage (U): National Academies Press.

• NAS, 2006. Safety and Security of Commercial Spent Nuclear Fuel Storage: Public Report. National Academies Press. Available at https://www.nap.edu/catalog/11263/safety-and-security-of-commercial-spent-nuclear-fuel-storage-public.

• NAS, 2016. Lessons Learned from the Fukushima Nuclear Accident for Improving Safety and Security of U.S. Nuclear Plants: Phase 2. National Academies Press. Available at https://www.nap.edu/catalog/21874/lessons-learned-from-the-fukushima-nuclear-accident-for-improving-safety-and-security-of-us-nuclear-plants.

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Dry cask sabotage:Outlier events

Edwin S. Lyman, PhD

Director of Nuclear Power Safety

Union of Concerned Scientists

Washington, DC

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Security reductions at decommissioning power reactors

• NRC security regulations are essentially the same for operating and decommissioning reactors

• Power reactors are required to protect against the “design basis threat” of sabotage to the reactor core or spent fuel

• Requires an armed response force to interdict external attackers• ISFSIs benefit from the presence of the security force although the NRC has not required that they be

protected to the same level as spent fuel pools

• But NRC has allowed decommissioning reactor licensees such as San Onofre to make changes to their security plans that (they assert) do not reduce their effectiveness

• Eliminate annual force-on-force exercises (once all spent fuel is in the ISFSI)• Eliminate cyber security program

• Also, the NRC no longer conducts triennial force-on-force inspections

• As a result, spent fuel pools and ISFSIs become more vulnerable to sabotage at decommissioning plants

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Enhancing off-site dose consequences

• As Dr. Crowley has shown, sabotage attacks on dry storage casks typically have limited dose consequences

• Only a small breach that limits particulate generation and release

• Absence of ongoing processes that would drive enhanced radionuclide release

• However, the NRC staff has identified additional modes of sabotage attack that could cause greater radionuclide releases from dry casks than previously assumed

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NRC Draft Technical Basis for ISFSI Security Rulemaking, Revision 1 (2010)

“Following the events of September 11, 2001, the NRC … evaluated several types of dry storage casks designs that were viewed as being representative of the entire population of dry storage ISFSIs... the assessments did challenge previous NRC conclusions on the ability of a malevolent act to breach shielding and/or confinement barriers and thus release radiation or radioactive material; and indicated that increased security requirements were warranted for specific scenarios such as these … In response to this new information … the NRC staff developed Commission policy paper SECY-07-0148 to update the ISFSI security requirements …”(https://www.nrc.gov/docs/ML0932/ML093280743.pdf)

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SECY-07-0148 (Enclosure 4), 8/2007

• However, … the [NRC] staff acknowledges that uncertainty exists on whether additional weapons capabilities may pose a vulnerability to spent fuel storage casks … an adversary's use of certain types of explosive attacks (using either manufactured or improvised devices)—which the Commission has required certain non-reactor licensees, but not ISFSIs, to defend against—may have the potential to breach some cask designs' confinement barrier and thus cause a radiological release that would exceed the 0.05-Sv (5-rem) dose limit at the ISFSI's controlled area boundary. This uncertainty has only been partially assessed by staff, but would involve, for example, adversaries using explosives to create kinetic, shear, or hydrodynamic weapons effects.”

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S.G. Durbin and C.W. Morrow, “Analysis of Dose Consequences Arising from the Release of Spent Nuclear Fuel From Dry Storage Casks,”

SAND2013-0533, January 2013Rte. 5

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Additional security measures

• The NRC 2010 Draft Regulatory Basis proposed that if these enhanced adversary attack modes could result in unacceptable off-site dose consequences (defined as more than 5 rem), the new rule should require additional security measures for ISFSIs, such as

• Increasing distance to controlled area boundary• Adding engineered security features/barriers• Shifting to a “denial” protective strategy: preventing

attackers from gaining physical access to the dry storage casks

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ISFSI security rulemaking history

• 2007: The NRC approved moving forward with a rulemaking to address the new vulnerability assessment information as well as other issues

• 2009: Staff issued draft regulatory basis

• 2015: The NRC approved staff recommendation to delay rulemaking by five years

• 2018: The NRC limited the scope of the rulemaking to codifying post-9/11 orders

• 2019: Staff proposed discontinuing the rule entirely

• 2020: The NRC has not issued a decision but is likely to accept the staff recommendation

• The vulnerabilities first discovered 15 years ago will not be rigorously addressed

• The ability of the San Onofre ISFSI to withstand enhanced adversary attack modes without causing off-site doses in excess of 5 rem is not clear

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SONGS ISFSI-Only

Security Plan

Ross Quam

Security Manager

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Summary of ISFSI-Only Security

• Purpose: safely protect spent fuel against radiological sabotage• Key elements:

– Various types of searches can be used– Integrated intrusion detection / video surveillance system– Requirement to interdict and neutralize threats does not apply to the ISFSI;

however, SCE will maintain the capability to do so in order to protect security personnel (or others) as appropriate to maintain ISFSI protection

– Insider mitigation for all personnel authorized to access ISFSI– Vehicle barrier system to protect against vehicle-borne explosives– Trained on-site response force– Maintain Law Enforcement Response Plan with local law enforcement

Above and beyond NRC requirements

SONGS

Emergency

Planning

Kelli GallionSr. Manager, Emergency Planning & Preparedness

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To protect the health and safety

of the public and our workers

Our Mission

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SONGS Emergency Plan

• With all spent fuel in dry storage, there are no accident scenarios that would result in an offsite radiological release

82 Emergency

Action Levels• Reactors

Operating

18 Emergency

Action Levels

• Reactors Permanently Defueled (2013)

3 Emergency

Action Levels

• All Spent Fuel in Dry Storage (2020)

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SONGS Emergency Plan

• Emergency Classification Levels– An operating plant has four classification levels, while decommissioned plants have

two (lowest two [least severe] of the four)

• Unusual Event- (Lowest emergency class) Indicates a potential problem with operation of the plant. No offsite radioactive release. Officials are notified.

1. Damage to a loaded spent fuel canister» There is no release mechanism for the contamination to go beyond the

site boundary.» NUREG-1140 performed accident analyses for dry fuel storage and

determined the projected dose to be 3 millirem (one-third of the dose received from a routine dental x-ray) at 100 meters from the ISFSI, which is within the SONGS boundary.

2. Security threat directed at the site

• Alert-Indicates an event that could reduce the plant’s level of safety. No offsite radioactive release. Officials are notified.

3. Hostile Action within the ISFSI 73

SONGS Emergency Plan

• Maintain 24/7 on-shift trained and qualified emergency responders

• Maintain proficiency through required emergency response drills and training– Emergency classification and notification of offsite agencies– Radiological assessment and mitigation– Fire and Medical response with Camp Pendleton (CPEN) and agreement hospitals

• Ensure prompt notification of state and local agencies (Cal OES, Orange County, San Diego OES, CPEN)

– 15-minute electronic notification– 60-minute verbal notification

• Maintain Written Agreements with the following Offsite Emergency Response Organizations

– Camp Pendleton Fire and Medical: Firefighting, Rescue, Medical Response & Transport – Law Enforcement: State Parks, CHP, CPEN, FBI, OCSD– Mission Hospital and Tri-Cities Medical Center: Treatment of contaminated, injured workers 74

SONGS Onsite Emergency Response Actions

• The following actions will be taken in response to a damaged spent fuel canister. Let’s assume that an earthquake has been felt and validated.

– On-shift emergency responders will perform radiological surveys at the ISFSI to determine if there is damage to a canister. Damage is determined by a change in radiation levels.

– If damage has been determined to have occurred, then prompt notifications will be made to California Office of Emergency Services (OES), Orange County Sheriff Communications (Control One), San Diego OES, Camp Pendleton and the NRC

• Electronic notification within 15-minutes • Verbal notification within 60-minutes to the 4 agencies listed above including the NRC.

– Once OC has been notified, additional notifications are made to:• San Clemente, Dana Point, San Juan Capistrano and State Parks• San Clemente Emergency Management Representative notifies Capistrano Unified School

District. 75

SONGS Onsite Emergency Response Actions

• SCE will provide protective action recommendations to onsite personnel and offsite agencies, if applicable.

• For example, if it is determined that a canister is damaged, then the Emergency Director would likely “recommend” evacuation of the state beach adjacent to SONGS. California State Parks and Camp Pendleton would assist in the relocation of those individuals

• In the very unlikely event of a canister breach, on-site actions will be taken to control the spread of contamination. Typical controls include wetting, tenting/covering, ventilating and decontaminating.

• The local city/county/school officials make all protective action decisions deemed necessary to protect the public.

• State, federal, and local agencies will perform independent radiological monitoring around the site to independently verify radiological conditions. 76

Orange and San Diego Counties

Emergency Planning &

Response for Offsite Agencies

May 28, 2020 Community Engagement Panel

Outlier Events Workshop77

Local Coordination

• The Counties of Orange and San Diego along with local jurisdictions will maintain individual emergency response plans specific to the San Onofre Nuclear Generating Station.

• Local jurisdictions will continue to support local planning, drills, and exercises for nuclear emergency planning and response.

• Local jurisdictions will coordinate joint emergency planning activities through the Interjurisdictional Planning Committee.

78

Jurisdictional Emergency Plans

• County and City Emergency Operations Plans– Basic Plans

– Functional Annexes

– Hazard-Specific Annexes and Appendices

• County SONGS Specific Emergency Plan– Interjurisdictional Policies

– Offsite Dose Assessment

– Emergency Protective Actions

– Recovery

79

Orange County

• Response to an emergency at SONGS– Begins with notification of a situation

• Call into Control One (24 hour warning point for Orange County or 9-1-1

– First Responders arrive & simultaneously impacted jurisdictions will be notified by Control One

– Incident Commander determines response posture & public protective actions

• Initial size up and protective actions will be determined• Radiological Monitoring Teams will be organized• Offsite Dose Assessment Center will be activated• County EOC may be activated to assist jurisdictions impacted and

coordinate response

80

Emergency Response Actions

• Key Current Procedures

– Law Enforcement

– Fire/Rescue

– Medical (EMS)

– Medical/Public Health

– Offsite Radiological Plume Monitoring

– Emergency Operations Center Activation

– Multi-Agency Coordination

– Exercises and Drills

– Decontamination

– Public Information/ Notification

– Training

81

Alert, Warning & Notification in

San Diego & Orange Counties

As related to SONGS Decommissioning

Stephen Rea

Assistant Director

County of San Diego

Office of Emergency Services

Stephen.rea@sdcounty.ca.gov

82

Emergency Action Levels

• Current emergency plans call for Edison to notify San Diego and Orange Counties of an “Unusual Event” or “Alert” at the plant within 15 minutes of the event.

83

Multimodal Alert, Warning and Notification

84

Wireless Emergency Alerts (WEA)

WEA Types:

• Imminent Threat Alerts that include extreme weather, and other threatening emergencies in your area;

• Public Safety Alerts that are less severe in nature than Imminent Threat Alerts;

• AMBER Alerts;

• Presidential Alerts during a national emergency; and

• Test Messages that are opt-in messages to support state and local WEA testing

85

Public Safety Alert

• An emergency may happen near the plant, members of the public could receive Public Safety messages for these types of incidents.

86

Imminent Threat Alerts

• Emergency evacuation and sheltering may occur in the vicinity of the decommissioned plant

• Local or State Emergency

87

Cell Tower Map

88

89

Outlier Events and Response StrategiesRecap

David Victor and Doug Bauder

90

BREAK

91

Public Comment

Submit written comments to: nuccomm@songs.sce.com

For Internal Use Only

92

CLOSING COMMENTSDAVID VICTOR AND DOUG BAUDER

For Internal Use Only

93

For Internal Use Only

2020 CEP Meetings

Planned Focus Topics

1Q CEP Meeting – Decommissioning and fuel transfer operations2Q CEP Meeting – Outlier events and response strategies

3Q CEP Meeting*4Q CEP Meeting*

Subject to Change

* Topics to be determined

94

Thank youStay safe and healthy

For Internal Use Only

95

For Internal Use Only

Acronyms

For Internal Use Only

96

APPENDIX

Initial commentsWorking Group• Doug Bauder - SCE VP and Chief Nuclear Officer, SONGS Decommissioning

• Donna Boston - County of Orange Emergency Management

• Manuel Camargo - SCE Strategic Planning & Stakeholder Engagement

• Katie Day - Surfrider Foundation

• John Dobken - SCE Public Information Officer

• Kelli Gallion-Sholler - SCE Emergency Planning

• Randall Granaas - SCE Fuels Engineering

• Gary Headrick - San Clemente Green

• Ace Hoffman - San Clemente Resident

• Tom Isaacs - SCE Experts Team & Independent Strategic Advisor for Nuclear Waste

• Roger Johnson - San Clemente Resident

• Torgen Johnson – Solana Beach Resident

• Jerry Kern - CEP Secretary

• Stephen Rea - County of San Diego Emergency Management

• Lorraine Sandstrom - SCE Community Affairs & Relations

• Jerry Stephenson - SCE Manager, ISFSI Engineering

• Dan Stetson - CEP Vice Chairman

• David Victor - CEP Chairman

97

RADIOACTIVITYAND

CONTAMINATION

DR. PATRICK PAPIN

98

APPENDIX

RADIOACTIVE DECAY

• Half-Life (constant value)• Time required for the number of

radioactive atoms to be decreased by a factor of one half

• Activity (value decreases over time)• Number of decays (disintegrations) of

the radioactive atom per time elapsed

99

BIOLOGICAL DAMAGE Absorbed Dose x RBE = Dose Equivalent• Relative Biological Effectiveness (RBE)

• Beta, Gamma, X-Rays = 1

• Neutrons = 10

• Alpha = 20

• Passing radiation encounters living cells.

• May destroy the cells ability to function, repair, or divide normally.

• Most damage results when the radiation absorbed energy breaks chemical bonds and ionizes molecules.

• Radiation (except in extreme conditions) damage is not due to heat transfer to the cell.

• Example-a whole-body dose that results in a 50% chance of death only increases body temperature equivalent to one sip of tea!!

100

TIME-DISTANCE-SHIELDING• Basic idea--minimize exposure!

• Minimize your TIME near sources of radiation.

• To reduce the number of radioactive particles you will encounter at any distance from source.

• Maximize your DISTANCE from a radioactive source.

• Alpha particles can travel 1-2 centimeters in air.

• Beta particles can travel up to 10 feet in air.

• Gamma Radiation and X Rays-

• Intensity decreases similar to how sound and heat intensity decreases with distance.

• Double the distance and the intensity will decrease by a factor of four.

• Neutrons—

• Intensity also decreases similar to how gamma radiation and x-ray intensity decrease with distance.

101

DOSE• Absorbed Dose-

• A general term denoting the quantity of energy absorbed in any material from electromagnetic radiation (x-and gamma ray) and particulate radiation (e.g. alpha particles, beta particles, neutrons).

• Common units-the Rad and the Gray.

• Dose Equivalent.

• Calculated by multiplying the absorbed dose by a factor (RBE) that depends on the type of radiation.

• Different types of radiation lead to various biological damage.

• Gives us the ability to make relative comparisons of biological effects as a result of receiving absorbed dose from various radiation types.

• Most significant quantity utilized by regulatory agencies for determining radiation use guidelines to workers, general public, and the environment.

• Common units-the REM and the Sievert. 102

ANNUAL DOSE TO GENERAL PUBLIC IN THE USA (620 mrem)

103

RADIATION DOSE LIMITS• Federal Occupational Dose Limits

• 5000 mrem per year

• Reference 10CFR 20.1201 https://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1201.html

• SONGS Administrative Dose Limits

• 1500 mrem per year (onsite plus offsite dose)

• Federal and SONGS Limits for a member of the public

• 100 mrem per year

• For a worst-case scenario at the ISFSI, SONGS complies with a 5,000 millirem (5 rem) dose limit at the SCE-controlled “fence line”

• SONGS Effluent limits are very small compared to public limits.

• Reference 10CFR 20.1301 and 10CFR 50 Appendix I

• https://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1301.html

• https://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appi.html

104

SONGS RADIATION DOSE

• SONGS owner controlled area-dose is equivalent to natural background

• Thermo-luminescent dosimeters (TLD) monitor dose

• TLD are placed within multiple sectors around the plant

• Measured Dose—approx. 80 mrem per year

• Reference: 2018 Annual Radiological Environmental Operating Report

• Available on the songscommunity.com website

• https://www.songscommunity.com/internal_redirect/cms.ipressroom.com.s3.amazonaws.com/339/files/20196/2018%20Annual%20SONGS%20Rad%20Enviro%20Operating%20Report.pdf

105

CONTAMINATION

• Radioactive material present in any substance, area, or on any surface where it is unwanted or unexpected

• Can be airborne, within the water supply, and in general terrestrial

• External – on the outside of the body

• Internal – within the body following an intake by ingestion, inhalation, skin absorption, or wounds

106

REFERENCES• Annual Dose Perspective Chart:

• NCRP Report 157, Radiation Protection in Educational Institutions, 2007• NCRP Report 160, Ionizing Radiation Exposure of the Population of the United

States, 2009• Nuclear Regulatory Commission, www.nrc.gov• San Onofre Nuclear Generating Station Annual Radioactive Effluent Release

Reports

• Federal and SONGS Administrative Dose Limits:

• Reference 10CFR 20.1201

https://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1201.html

• Reference 10CFR 20.1301 and 10CFR 50 Appendix I

https://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1301.html

https://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appi.html

107

Appendix• Definitions:

– Mechanistic: relates to theories that explain phenomena in purely physical or deterministic terms; by physical processes alone

– Postulated: defined as “assume the existence of”

– Radiolysis: molecular decomposition of a substance (H20) by ionizing radiation into elemental species (H2 and O2)

• References:– PNNL-6365: Evaluation of Cover Gas Impurities and Their Effect

on Dry Storage of LWR Spent Fuel

– CNWRA-NRC-02-07-C-006, 2013:

• L. Miller et al, “Vacuum Drying Test Plan – Public version”

• H. Jung et al, “Extended Storage: Evaluation of Drying Adequacy”108