1 Site Visit Report

San Onofre Nuclear Generating Station (SONGS)

14300 Mesa Road San Clemente, CA 92674 September 2, 2009

1.0 Background and Objectives

The Environmental Protection Agency (EPA) is in the process of developing 316(b) cooling water intake structure requi rements that reflect the best technology available (BTA) for minimizing adverse environmental impact for all existing power plants and manufacturing facilities. As part of this process, EPA staff is visiting electric generato rs and manufacturers to better understand the cooling water intake structure (CWIS) technologies in use at facilities, including the sitespecific characteristics of each facility and how these affect the selection and performance of CWIS technologies. EPA is also visiting f acilities to better understand cooling water use and specific is sues or technologies that can affect 316(b) compliance. San Onofre Nu clear Generating Station (SONGS) was

selected for a site visit due to its ocean withdrawal location, its fish return system, and because it generates a significant am ount of power (as a percentage of the total) for the state of California.

2.0 Facility Description

SONGS is located on an oceanfront site n ear the city of San Clemente (between Los Angeles and San Diego) and began opera tions in 1968. The facility is located on land leased from the U.S. Marine Corp s’ Camp Pendleton. SONGS is divided into two areas; the beachside portion (where the reactors and other power generation equipment are locate d) is approximately 84 acres, 1 while the upland portion (referred to as the Mesa Comp lex, across the freeway and home to administrative operations) is approximately 130 acres. 2 The facility is principally owned by Southern California Edison (SCE) 3 and employs approximately 3200 workers. The facility’s NPDES pe rmit (CA0108181) expires May 11, 2010 and facility representatives have begun prep aring renewal applic ation materials.

1 Facility representatives stated that SONGS is the most compact nuclear power plant site in the U.S. By comparison, the Fort Calhoun Station, the smallest nucl ear facility by rated output at 482 MW is located on 660 acres of land, near Omaha, Nebraska. Source: http://www.nei.org/resourcesandstats/n uclear_statistics/usnuclearpowerplants

2 The facility’s beachside main portion is located s outh of San Onofre State B each alongside the Pacific Ocean. The San Diego Freeway (Interstate 5) and a hi gh speed railway parallels the eastern boundary and separates the beachside main po rtion from the up land portion.

3 SCE owns a 78.21% stake in the facility.2 3.0 Electricity Generation and Transmission

SONGS operates two nuclear reactors (Un its 2 and 3) with a total generating capacity of 2254 MW. 4 The facility is a baseload generator, with a capacity utilization rate (C UR) of 83% in 2006. 5

Routine refueling outages o ccur approximately every 18 months. The facility has completed its Unit 2 steam generator repl acement, which resu lted in a 197 day outage. The process involved removal of portions of the containment wall of the reactor. The same procedure for Unit 3 is expected to occur this fall; however, the outage for Unit 3 is exp ected to last only 97 days.

4.0 Cooling Water System and Intake Structure

SONGS operates two submerged offshore intakes (one for each unit) to withdraw once-through cooling water from the Pacific Ocean. 6 Each intake pipe is fitted with a velocity cap 7 and is located approximately 3200 feet offshore at a depth of 32 feet. The through-screen velocity at th e velocity cap is approximately 1.5 feet per second (fps). After water en ters the intakes, it is th en transported to a forebay onshore. The forebay is divided into tw o identical halves, one for each generating

unit.

Vanes and louvers angled at 30 degrees to incoming flow change the water velocity and guide fish to a quiet zone at the inland end of the forebay, where fish avoid the traveling screens and instead ar e collected in a fish handling chamber and periodically returned to the ocean via a fish elevator. The elevator is operated once per shift 8 and returns fish to a conduit back to the ocean approximately 1900 feet offshore. Facility representatives noted that this system results in high survivability and that the survival rate varies depending on the species; a study in

2006-2007 demonstrated that 71.6% of all fish es entrained were returned to the ocean via the Fish Return System (CDS 2008).

The cooling water and remaining fish a nd debris then pass through a set of bar racks and a pair of vertical traveling sc reens; water first passes through the 1”

4 Unit 1 was retired in 1992 and is decommissioned. Units 2 and 3 began operations in 1983 and 1984, respectively.

5 The facility’s CUR was 90% in the late 1990s. It pr ovides nearly 20% of the electricity to southern

California.

6 The intake and discharge tunnels for Unit 1 still exist, but have been capped. The NPDES permit for this

unit has been terminated.

7 The facility has not installed marine mammal exclusion bars that are found at other velocity caps. Facility representatives stated that obtaining approval to in stall them takes considerable time and they still have concerns over clogging from kelp. Approximately 30 Pacific harbor seals and California sea lions per year reach the forebay, where they are ca ptured and returned to the ocean.

8 The elevator is operated at a diffe rent time during each shift to disc ourage predation at the fish return.3 mesh screens and then the 3/8” mesh screens. 9 Screens are rotated manually or based on a pressure differential and are cl eaned by a high pressure spray. Debris (including any impinged fish) is collected in a dumpster for disposal at a landfill. The through-screen velocity at the trav eling screens is approximately 2.8 fps.

Each unit has four circulating pumps, each rated for 298 million gallons per day (mgd); the total design intake flow (DIF) for SONGS is 2384 mgd. 10 The facility’s average actual intake flow (AIF) is approximately 2400 mgd. The delta T for the condenser is typically 19-20oF.

Facility representatives stated that the CWIS design is unique and was an expensive undertaking when the facili ty was built (approximately $200 million).
In fact, the reactors are bu ilt adjacent to the CWIS.

Unit 2’s discharge is located 6300 feet o ffshore at a depth of 50 feet; Unit 3’s discharge is 8600 feet offshore at a sim ilar depth. Each generating unit has its own discharge pipe with 63 diffusers.

5.0 Impingement and Entrainment Information

SONGS has conducted studies of its veloci ty cap and facility representatives stated that, in conjunction with the fish elevator, impingement mortality has been reduced by 97%. Facility repr esentatives stated that the velocity cap reduces the

number of fish drawn into the intake stru cture by at least 90%. Initial studies of the fish elevator suggest that fish exhi bit survival rates of 75-96% and further studies (spanning 11 years) i ndicated an average survival rate of 70%. Facility representatives noted that daily losses due to impingement are estimated to be 0.15 tons while those due to sport fi shing are estimated to be 12.4 tons.

The facility also submitted a Compre hensive Demonstration Study to the San Diego Regional Water Quality Control Board, as required by the now-suspended 2004 Phase II rule. Facility representatives st ated that biological studies represent a snapshot of ambient conditions at the offshore intake location and are compared

to measurements taken near the shore. Typically, spring is the season with the highest abundance of entrainable or ganisms, i.e., eggs and larvae.

Facility representatives stated that the offshore sardine population has rebounded significantly with the establishment of state fishing regulations. A study in 2005- 2006 indicated a large difference in impinged fish at one intake (as compared to the other). In all, 3 speci es represent 97% of the fi sh impinged at both units.

9 There are six pairs of screens in eac h half of the CWIS. Facility representatives noted that the first set of screens is constructed of a composite material and th e second set is stainless steel. They added that improvements to the chain and bearings have resu lted in these screens bein g in place for 13 years.

10 The facility’s service water system (which provid es cooling for th e auxiliary reactor systems) is withdrawn from the circulating water flow.4 6.0 Cooling Tower Feasibility

Facility representatives have studied clos ed-cycle cooling in detail, but maintain that it is not an appropriate solution for SONGS. Facil ity representatives stated that the facility could face significant obs tacles in retrofitting to closed-cycle cooling, including finding a suitable location, 11 obtaining PM10 offsets, 12
obtaining construction permits, gaining appr oval from the Marine Corps to build

towers, 13 and to obtain permission from st ate regulators for a $3.12 billion expenditure. 14

An independent third-party feasibility study conducted by Enercon Services, Inc. of Atlanta, GA, concluded that the only space available for cooling towers would be on the Mesa complex. They noted substantial engineering challenges associated with cooling towers at th e Mesa complex, incl uding massive earth moving projects for the large piping re quired beneath the highway, building relocation, potential for flooding, 15 an energy penalty of 191 MW, potential condenser replacement, and significant pl ume and visual impacts. Facility representatives also noted potential impacts to activities at Camp Pendleton, such as impacts to training areas, plume eff ects on flight operations, salt drift in residential areas, and noise and aesthetic impacts.

As part of its process developing a st atewide OTC policy, the California State Water Resources Control Board recently evaluated all coastal OTC facilities, including SONGS, to determine the feasib ility of retrofitting each location with closed-cycle cooling. A survey report of a ll coastal facilities prepared for the CA

Ocean Protection Council and State Water Board in 2008 16 concluded that, while a retrofit was technically feas ible at SONGS, significant obstacles would have to be overcome. The report noted the site’s compact size and proximity to sensitive coastal habitats and high use transit corrido rs as factors that would likely require (1) additional consultation with resource ag encies to secure the necessary permits

11 Facility representatives stated that the towers could not be located at the beach site; the parking lots and other open spaces are not large enough for plume abat ed towers, which facility representatives noted need more space in order to prevent recirculation of th e plume into the towers. In addition, facility representatives stated that the towers likely cannot be built near the state beaches and that spent fuel storage activities are required to remain within the power block.

12 Enercon estimated that the towers would emit 827 tons of PM10 per year, but only 150 tons per year are available in the permitting process.

13 Facility representatives noted that the Marine Co rps has committed land in th e vicinity of SONGS as natural habitat and green space; close-cycle cooling ma y impact the ability to continue to designate that space as natural.

14 Facility representatives stated that they expect a 5% rate increase and a 17 month outage, adding that Diablo Canyon would likely cost approximately $4 billion. They noted that SCE recently struggled to gain approval for $700 million turbine improvements, whic h serve to add generating capacity; cooling towers would remove capacity from the grid.

15 Facility representatives stated that, if the towers were built at the Mesa Complex, they would be at a higher elevation; should the facility lose power, the water in the towers would flow downhill, possibly flooding the plant.

16 Tetra Tech, Inc. California’s Coastal Power Plants: Alternative Cooling Systems Analysis. February 2008. This report was prepared under cont ract to the CA Ocean Protection Council.5 to construct towers in sensitive areas, and (2) plume-abated towers to reduce potential safety hazards on nearby freeway s. If the first condition could not be met, the report considered a Unit 3 retrofit infeasible due to lack of space; plume

abated towers were still consider ed feasible for Unit 2, however.

The 2008 report did not evalua te siting towers at the Mesa Complex in detail, citing the difficulty in constructing four 12-ft diameter tunnels beneath the railroad and the San Diego Freeway. Cost estimates were not developed for a Mesa installation, although the report notes that they would likely be significantly higher than a beachside installation.

7.0 Debris Handling

Facility representatives did not identify any significant proble ms with debris. They estimated that the facility disposes roughly 1 ton of seaweed and kelp (wet weight) per day.

8.0 Repowering/Future Uses

Facility representatives were not aware of any plans for repowering or adding new generating units.

9.0 Cooling Ponds

There are no cooling ponds onsite.

10.0 Ownership

SONGS is owned by Southern California Edison, an investor-owned company and subsidiary of Edison Internationa l. SONGS is jointly owned by SCE (78.21%), San Diego Gas & Electric (20%), and the city of Riverside (1.79%), but SCE maintains full operati ng management of SONGS.

11.0 316(a)

As noted in Section 4.0 above, SONGS uses an offshore discharge with diffusers. The discharge is designed to meet Ca lifornia’s thermal plan, which allows no more than a 4oF change within 1000 feet. Facility representatives noted that typical temperature changes are 1-1.5oF and that many other power plants in

California do not meet the state standard.

12.0 Ash Handling

SONGS does not use coal as a fuel and therefore has no ash ponds.6 13.0 Air Emissions Controls

EPA did not collect any information regarding air emissions controls.

14.0 Additional Information

Facility representatives di scussed intake technologies , as outlined in the 2008 CDS, that have been considered for reducing impingement and entrainment at

SONGS. 17 Technologies that were considered but deemed infeasible by the facility’s analysis included variable sp eed pumps, an aquatic filter barrier, and

relocation of the CWIS. SONGS determ ined that fine mesh modified or cylindrical wedgewire scr eens could be feasible (based on many assumptions; refer to CDS 2008), but would likely fall s hort of the performance criteria in the now suspended Phase II 316(b) rule. SO NGS indicated the ex tensive footprint associated with wedgewire screens woul d likely have a substantial impact on

offshore habitat.

Facility representatives noted that spent fu el storage facilities (for all three units) are being constructed on th e former site of Unit 1.

Facility representatives stated that, as a preventive maintenance measure for biofouling, the facility conducts heat trea tments where the direction of flow is

reversed and heated effluent is di scharged through the intake pipes. 18 Prior to the heat treatment, operators slowly raise the temperature within the piping, herding fish towards the fish elevator; frequent ope ration of the elevator returns the fish to the ocean. Facility representatives noted that they often encounter large numbers of subadult and adult fishes during these events, especially in summer. They added that operators see resident fish in the forebay for weeks at a time.

Facility representatives noted that SONGS is critical to the future of California’s energy needs, including plans for greenhous e gas emission reductions statewide. They noted that it is difficult to integrat e renewable energy sources to the grid and noted that state analyses of grid reliabili ty may be changing. They also noted that the wildfires in 2009 have delayed permitting for renewable energy projects. They added that the proposed Californi a rule for closed-cycle cooling would require them to begin retrofitting in 2020, when state greenhouse gas goals will take effect, limiting the state’s ability to meet those goals.

Facility representatives stated that the California Coasta l Commission (CCC) has recently stated that, in its judgment, m itigation measures would be sufficient to qualify as “best technology available” for SONGS.

Facility representatives stated that, unde r the 2004 Phase II rule , they were likely to pursue the cost-benefit test or restor ation to meet the rule requirements.

17 See Attachment D for detailed information on each technology.

18 Heat treatments are as frequent as every 6 weeks in summer, the high biofouling season.7 Attachments

Attachment A List of Attendees

Attachment B Aerial Photos

Attachment C PowerPoint Presentatio n “The Once-Through Cooling Rule for Existing Power Plants” September 2, 2009 Attachment D Comprehensive Demonstr ation Study for Southern California

Edison’s San Onofre Nucl ear Generating Station8 Attachment A--Lis t of Attendees

Paul Shriner, EPA Jan Matuszko, EPA Tim Havey, Tetra Tech Kelly Meadows, Tetra Tech David Asti, Southern California Edison Patrick Tennant, Southern California Edison Robert Heckler, Southern California Edison Robert Keller, Southern California Edison

# Copyrighted page/s removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder.

Please contact the EPA Docket Center, Public Reading Room to view this document.

Address: 1301 Constitution Ave, NW

Room 3334 Washington, DC 20004

Telephone: 202-566-1744

Fax: 202-566-9744
Email: docket-customerservice@epa.gov10 Attachment C--PowerPoi nt Presentation

Please see the attached materials.

Attachment D—Comprehensive Demonstr ation Study for Southern California Edison’s San Onofre Nuclear Generating Station

Please see the attached materials.