20-0203_SAN ONOFRE NUCLEAR GENERATING STATION_Memorandum of Understanding MOU Between the California Department of Public Health: Radiologic Health Branch, the City of San Juan
Capistrano, California State Parks and Southern California Edison
MEMORANDUM OF UNDERSTANDING :
THE SAN ONOFRE NUCLEAR GENERATING STATION
INDEPENDENT SPENT FUEL STORAGE INSTALLATION
GAMMA RADIATION MONITORING SYSTEM
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61147.01100\32486285.3
MOU Between the.California Department of Public Health:Radiologic Health Branch, the..City of San Juan
Capistrano, California State Parks and Southern California Edison
Table of Contents
I. PURPOSE 3
II. BACKGROUND 3
III: . PARTIES 3
IV. RESPONSIBILITIES BACKGROUND 4
V. FINANCIAL SUPPORT 6
VI. TERM AND TERMINATION 7
VII: RELATIONSHIP OF THE PARTIES 7
VIII.MISCELLANEOUS 7
IX. CONTACTS. 8
X. Signature.Pages 10
ATTACHMENT 1- Real Time Radiation Monitor and Camera Network (System Description) 13
FIGURE 1- System Description Flowchart 14
FIGURE 2- Real.Time Radiation Monitor Locations 15
61147.01100\32486285.3 . 2
MOU Between the..California Department of Public Health::Radiologic Health Branch, the:City of San Juan
• Capistrano, California State Parks and Southern California Edison
I. PURPOSE.
This Memorandum of.Understanding (MOU) is entered into by and between:Southern California
Edison (SCE).and the.California Department of Public Health (CDPH)/Radiologic Health Branch
(RHB), the City of San Juan Capistrano (SJC), and California State Parks, In this MOU, SCE,
CDPH/RHB, SJC, and California State Parks are sometimes referred individually as"Party" and
collectively as "Parties;" and CDPH/RHB, SJC, and California State Parks are sometimes
referred collectively as the "Agencies".:
The purposeof this MOU is to memorialize theunderstandings of all signatory parties regarding
:the: (1) monitoring of gamma radiation in the vicinity of the San Onofre Nuclear Generating.
Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI), (2) supplying of a real
time data stream of radiation measurements recorded at the SONGS ISFSI; and (3) publication
of monthly reports regarding those radiation measurements for public review in accordance with.
Lease No. PRC 6785.1, authorized by the California State Lands Commission (CSLC), on March
21, 2019.
II.. BACKGROUND
A. SONGS ISFSI
The SONGS ISFSI is located in the area previously occupied by SONGS Unit 1. SCE is
storing spent nuclear fuel and radiologically contaminated materials in the SONGS ISFSI
pursuant to a. coastal development permit (CDP) granted by the California Coastal:
Commission
B. Real Time Radiation Monitoring
In accordance with Lease No. PRC 6785:1 Exhibit C (CSLC Mitigation Monitoring Program)
specifically, Mitigation Measure APM-23- prior to commencing decommissioning activities
for SONGS Units 2 & 3, SCE or its contractor will install and maintain an ISFSI gamma
radiation monitoring system (IRMS) to supply a real-time data stream of radiation
measurements to local and state agencies.
The IRMS will be comprised of three gamma radiation detectors to measure radiation levels
at the ISFSI.perimeter and one gamma radiation detector at a remote location to measure
background radiation levels.. The radiation detectors will be capable of measuring radiation
levels from 1 microrem/hour to 10 rem/hour. A complete description of the IRMS is included.
in Attachment 1:
Data from the IRMS will be provided in real time to the CDPH/RHB,'SJC,:and California State
Parks. CDPH/RHB will publish monthly reports'for public review summarizing high; low, and
average radiation: levels measured foreach. day. CDPH/RHB and SJC have the ability to
view the IRMS data, if desired. Such monitoring and reporting will continue until the spent
nuclear fuel has been removed from the SONGS site
61147.01100\32486285.3 • 3 •
MOU Between the.California Department of Public Health Radiologic Health Branch, the City of San Juan
Capistrano, California State Parks and Southern California Edison
•
HI. PARTIES
The Parties to this MOU are SCE, CDPH/RHB, SJC, and California State Parks.
A. California Department:of.Public Health: Radiologic Health Branch
CDPH/RHB enforces the laws and -regulations.designed to protect the radiological health of
thepublic, radiation workers, and the environment.. RHB specifically is .responsible for
providing public health functions associated with administering a radiation control program.
This.includes.surveillance of radioactive contamination in the environment. CDPH/RHB is
willing to participate in satisfying the requirements of,APM-23.
B. City of San Juan Capistrano
SJC is, in part, within the original emergency planning zone of SONGS. Thecity is willing to.
participate in satisfying the requirements of APM-23, but only as specifically set forth in .this
MOU.
C. California State Parks
The San Onofre State Beach, San Onofre Bluffs, Sa n Onofre-San Mateo Campground and
-SanOnofre Surf Beach are within the originalemergency planning zone of SONGS.
California State Parksis willing to participate in satisfying the requirements of APM-23.
D. Southern California Edison
SCE is the majority owner and the operator of SONGS, including the SONGS ISFSI. As the
Decommissioning Agent and NRC s Licensee for SONGS, SCE :develops and submits
requests for various permits and .amendments necessary to safely and responsibly.
decommission :the SONGS . facility. As such_; SCE is responsible for satisfying the
requirements of.-APM-23. •
•
IV.: RESPONSIBILITIES BACKGROUND. : •
A: California Department of Public Health: Radiologic:Health Branch •
CDPH/RHB has the responsibility to provide physical infrastructure within their offices to host
the IRMS equipment used to receive the IRMS =real time data provided by SCE or its
contractor. This includesspace to locate a portable laptop computer, an electrical service
outlet, internet access and routing of thedata cable within the building [or similar).
SCE shall be granted physical accessto the. IRMSequipment during regular CDPH/RHB
working hours. SCE's physical,access tothe IRMS equipment outside of CDPH/RHB regular
working hours will be granted with the advanced consentof the CDPH/RHB.
61147.01100\32486285.3 4
MOU Between the California Department of Public Health: Radiologic Health Branch, the City of San Juan
Capistrano, California State Parks and Southern California Edison
CDPH/RHB has the additional responsibility to approve and publish monthly reports for public
review summarizing high, low, and average radiation levels measured for each day. The
monthly reports will be published on the CDPH/RHB homepage. The link will also be
provided in the IRMS desktop instruction.
CDPH/RHB has the responsibility to ensure that the laptop is functioning by validating that
the laptop is receiving real time radiation measurement data.
CDPH/RHB will assist SJC and California State Parks with interpretation of the real-time
radiation monitoring data as needed.
B. City of San Juan Capistrano
SJC has the responsibility to provide physical infrastructure within one of SJC's facilities, to
host the IRMS equipment used to receive the IRMS real time data stream. SJC shall have
the sole authority to choose the facility and location of the IRMS equipment within the facility.
This includes space to locate a portable laptop computer, an electrical service outlet, internet
access and routing of the data cable within the building or similar space.
SJC's sole responsibility under this MOU is to provide space for the IRMS equipment, and
without limiting the nature of the following, SJC shall not be responsible for: monitoring the
IRMS equipment or data, interpreting or disseminating the radiation measurement data,
alerting any party as to presence, absence or nature of the radiation measurement data,
ensuring the provision of utility service (including electricity or telecommunication services)
to the IRMS equipment, or any damage or destruction to the IRMS equipment due to any
fire, earthquake, act of God, vandalism, or similar cause.
SCE shall be granted physical access to the IRMS equipment during regular SJC working
hours. SCE's physical access to the IRMS equipment outside of SJC regular working hours
will be granted with the advanced consent of the SJC.
C. California State Parks
California State Parks has the responsibility to provide physical infrastructure within their
offices to host the IRMS equipment used to receive the IRMS real time data stream. This
includes space to locate a portable laptop computer, an electrical service outlet, internet
access and routing of the data cable within the building [or similar].
California State Parks has the responsibility to ensure that the laptop is functioning by
validating that the laptop is receiving real-time radiation monitoring data.
SCE shall be granted physical access to the IRMS equipment during regular California State
Parks' working hours. SCE's physical access to the IRMS equipment outside of California
State Parks' regular working hours will be granted with the advanced consent of the California
State Parks.
61147.01100\32486285.3 5
MOU Between the California Department of Public Health: Radiologic Health Branch;the City of San Juan
Capistrano, California State Parks and Southern California Edison
D. Southern California Edison
SCE has the responsibility for onsite IRMS system design, installation and maintenance, and for coordination with the Parties to:provide .and. maintain hardware and software used for
• receiving the IRMS real-time data.. SCE has the.additional responsibilities to provide desktop
instructionsfor monitoring the real-time data, .producing the draft monthly. report for
CDPH/RHB's approval, providing initial training using SCE provided desktop instruction for
staff personnel designated by:the Parties upon system installation, and providing periodic
refresher training as needed orrequested by the Agencies:
SCE.will continue to maintain hardware and software used for monitoring and reporting until
all.spent nuclear fuel'has been removed from the SONGS site, after which time SCE will be
allowed to retrieve the hardware and software from the Parties.
SCE will provide the funding:set forth in:Section V.A for SJC and California State Parks until
allspent:nuclear fuel has been removed from the SONGS site, at which time SCE will
discontinue the the funding.
SCE will provide funding set forth in Section V.A for CDPH/RHB until allspent nuclear fuel
has been removed from the SONGS site, at which time SCE will discontinue the funding.
V. FINANCIAL SUPPORT
•
A. Invoicing & Payments
At the beginning of each fiscal year beginning on July 1, 2020; SJC and California State
Parks, Orange Coast District will each submit an invoice to SCE for the sum of $50,000.00 .
for hosting the equipmentand monitoring the real-time•data stream during that fiscal year.
At:the beginning of each fiscal year beginning on July.1, 2020, CDPH/RHB will submit an
annual invoice to SCE for the sum of$100,000.00 for hosting the equipment, monitoring the
real-time data, and publishing monthly reports during thatfiscal.year.
SCE will issue $50,000.00 each to SJC and California.State Parks, Orange-Coast District on
• an annual basis and. $100,000.00 to. CDPH/RHB annually until all spent fuel has been
removed from the SONGS site. . Payments will be made directly to each of the Agencies in
the form of one payment within 30 days,of receiving the invoice. Payments will be pro-rated
• for the first year followingthe effective date of this MOU andfor subsequent years in the.
• event of early termination:
B; Funding Duration
• SCE will continue to provide financial support set forth in section V.A for monitoring the real-
time data and publishing monthly reports until all spent nuclear fuel has been removed from
the SONGS site. .
61147.01100\32486285.3 6
MOU Between the California Department of Public Health: Radiologic Health Branch, the City of San Juan
Capistrano, California State Parks and Southern California Edison
VI. TERM AND TERMINATION
This.MOU is effective as of the date it is signed by the duly authorized representative from each
of the Parties. This Agreement shall remain ineffect until all.spent nuclear fuel hasbeen
removed from the SONGS site.. If any of the.Agencies desires to.terminate.the MOU prior to.
that time; it will.provide SCE with 60-days°advance.written noticeof its intent to terminate. In
that event, SCE will amend the MOU as necessary, including to add a replacement local or state
agency.
Upon the termination of this Agreement, SCE shall remove the IRMS equipment, at SCE's
expense, and'shall return the host facility to the condition it existed prior to this Agreement,
normal wear-:and tear e xcepted, unless otherwise agreed by. the CDPH/RHB, :SJC, and/or
California State Parks: -
VII. RELATIONSHIP OF.THE PARTIES
The Parties acknowledge and agree thatthe activities performed by any entity, its employees,
agents or sub-contractors shall be under the purview of their respective entity and that nothing •
in this MOU shall be deemed to constitute a partnership, joint venture, agency relationship or.
otherwise between the.Parties: •
The reimbursement from SCE to the Parties for related expenditures should not be:construed
• as allowing any Party to influence or direct the independent decision-making and direction of
individual Parties. Each Partymaintains responsibility for its own actions or inaction.
VIII. MISCELLANEOUS •
A. This MOU nor. the IRMS replaces or supplements the existing onsite or offsite SONGS.
emergency response plan capabilities: No Party shall rely on, act on, or-make emergency
response decisions based on the:IRMS data: The IRMS isfor information only. .
B. The failure of any Party to enforce its rights under this MOU at any time for any period
shall not be construed as a waiver of such rights.
C. _ If any part,term, or provision of this MOU is held to be illegal or unenforceable,.neither
the validity nor enforceability of theremainder of this MOU shall be affected.
61147:01100\32486285.3 7
MOU Between the.California Department of Public Health::Radiologic Health,Branch, the City of San Juan
Capistrano, California State Parks and Southern California Edison
D. No Party shall assign or .transfer all or any part of its rights or responsibilities under. this.
MOU without express written consent of SCE: Notwithstanding:the prior sentence, SCE
may assign this Agreement, without prior consent; toany entity that may be created or
• designated by SCE to act OS.Decommissioning Agent to'oversee the decommissioning
of SONGS, provided, such entity.agrees to perform the obligations assumed by SCE
herein.
E. This MOU constitutesthe entireunderstanding between the Parties relating to the subject_
matter hereof and . supersedesall prior representations, writings, negotiations or
understandings regarding this matter.
:F. This MOU may only.be modified by the written agreementof the Parties, duly signed by
their authorized representatives.
G. This MOU has been negotiated andexecuted in the State of California and shall be
governed under the laws of the State of California. :In the event'of any legal actionto.
• enforce or interpret this MOU, the sole and exclusive venue shall be a court of competent
jurisdiction located within the county of the Party the dispute arises with, and the Parties
hereto agree to and do hereby submit to the jurisdiction of such court, notwithstanding
Code of. Civil Procedure Section 394. :
H. This.MOU may be executed in counterparts, and upon execution by all Parties, each
executed counterpart has the same force and effectas an original instrument, and as if
all Parties had signed the same instrument. Any:signature page maybe detached from
any counterpart without impairing the legal effect of any signatures thereon and maybe
attached to another counterpart identical in form hereto but having attached to it one or
: more signature pages.
IX. CONTACTS.
Each Party has designated a primary contact for purposesof administering this MOU as follows:
Southern California Edison: -
Kelli A. Gallion
Emergency Planning-Manager
Southern California Edison Company
5000 Pacific Coast Highway
Mail Stop; D2A.
San Clemente, CA 92672
(949) 368-7756
61147:01100\32486285.3 8
MOU Between the California Department of Public Health: Radiologic Health Branch, the City of San Juan
Capistrano, California State Parks and Southern California Edison
California Department of Public Health: Radiologic Health Branch:
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San Juan Capistrano:
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California State Parks:
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Each Party shall advise all other Parties in writing when there is a change to its primary contact
under this MOU. The MOU need not be amended to reflect changes in contact information.
However, if during the pendency of the MOU it is amended for other reasons, the contacts
information shall be updated at that time.
61147.01100\32486285.3 9
MOU Between the California Department of Public Health: Radiologic Health Branch,the City of San Juan
Capistrano, California State Parks and Southern California Edison
X. Signature Pages
Signature.Page
California Department of Public Health::Radiologic.Health Branch
California Department of Public Health: . . Southern California Edison
Radiologic Health Branch
By: By: .
(Signature) (Signature)
Name: . Name: .
Title: Title:
Date:. Date:
Contact information Contact information
Telephone: . Telephone:
E-mail: E-mail: .
61147.01100\32486285.3 . 10
MOU Between the California Department of Public Health:.Radiologic Health Branch,the City of San Juana
Capistrano, California State Parks and Southern California Edison
Signature Page . . . .
City of San Juan Capistrano
City of San Juan Capistrano Southern California Edison
B �� // B
By: y:
ig ure) (Signature)
Name: E2çJUThY ley Name:
Title: . @Jc COO . Title:
Date: 2-- 3 -24 Dater
Contact information Contact information
Telephone:. (� U��r�P6I6 Telephone:
E-mail: leO6te94v1JU_i1e O- E-mail:
•
61147.01100\32486285.3 . 1 1
MOU Between the California Department of Public Health:Radiologic Health Branch, the City of San Juan
Capistrano, California State Parks and Southern California Edison
•
Signature Page
California State Parks
California State Parks Southern California Edison
By: By:
(Signature) (Signature)
Name: Name:
Title: Title:
Date: Date:
Contact information Contact information
Telephoner Telephone:
E-mail: E-mail:
•
61147.01100\32486285.3 12
MOU Between the.California Department of Public Health: Radiologic Health Branch, the.City of San Juan
Capistrano, California State Parks and Southern:California Edison
ATTACHMENT 1- Real Time Radiation Monitor:and Camera Network (System Description)
•
Real-Time Radiation Monitor Description
In a commitment to the California State Lands Commission, Southern California Edison will install remote
radiation monitoring.equipment which will be used to send radiation monitor data to off-site agencies for public
consumption.
Overall Design Description.
A data network for the radiation monitor:equiprneht is described below. Figure 1 is a flowchart which.'
illustrates how data is collected and transferred for public consumption. Figure 2 illustrates the locations of thea
radiation monitors.
Radiation Monitor Network Design[Data Transfer].
The remote radiation monitoring equipment consists of four radiation monitors. Three radiation monitors will be
posted at various locations around the ISFSI and a fourth monitor will reside inside the Owner Controlled Area
near the Lot 4 fence line._ Data collected by the radiation monitors is sent to an adaptive wireless monitor
located on ISFSI Security Building roof.. This data is then sent to a switch in the ISFSI Security Building.
Telecommunications Room. This switch isconnectedto a server located in the Security Building Temperature
Monitoring Room, which collects the radiation monitor dataand sends back through the Telecommunications
Room switch to a series of two switches in the Microwave Building on the south end of the switchyard via fiber.' •
Data comingoff the second switch Microwave Building is sent on a secure communication path to laptops
located at offsite agencies as well as a laptop.located on Site,for Engineering use:
Radiation Monitor Network Equipment Power,
The radiation monitors, which will be mounted to light poles, run on solarpower and have battery backup.
Power for the adaptive wireless monitor will be through Power over Ethernet (POE). A CAT6 Ethernet cable
will be connected from the adaptive wireless monitor to the switch locatedin the Security Building
Telecommunications Room. All downstream equipment is existing equipment and is currently powered.. .
:Bill of Materials (Major Components)
• Quantity 4 Mirion 900 MHz Radiation Monitors
• Quantity 1 Mirion AWM Wireless Gateway(adaptive wireless monitor)
• Quantity 1 Meraki SB.= MS225 24P (Telecommunications Room Switch) •
• Quantity 1 Hewlett Packard Enterprise ProLiant DL360 Gen10 Server
• . Quantity 2 Cameras Meraki MV74
• • Quantity 1 Cisco ASR-1001-X Switch
'Note: allequipment located in the microwave building'is existing equipment
•
61147:01100\32486285.3 • . 13
MOU Between the California Department of Public Health: Radiologic Health Branch, the City of San Juan Capistrano, California State Parks and
Southern California Edison
FIGURE 1- System Description Flowchart
DA= Decommissioning Agent/SCE
DA Network Drawing for ISFSI Real Time Radiation Monitoring.
Version 2.0 07/15/2019 _661/
RLW
OPS#1
Server
SDAOP5s01
Outbound traffic will These components are
already in place ® connection OPS#2
be through port ,
7118 and a port rule 2 i
will be created to #
only allow outboundil Marion
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p Marion90mhz Rad Monitor
1111111. $ d Mondor I.
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_�' Layer 2 Private VLAN 197 will be implemented
l § for this data stream,this is too isolate from
the DA domain.
8
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Meraki Outbound to Meraki Cloud i
(.........Cloud)1camera Viewing and Storage i
Review PC -i'— O•I-
re..
Network
Non DA Viewing— — -- - --- --w _. _-.i Camera Viewing
61147.01100\32486285.3 14
MOU Between the California Department of Public Health: Radiologic Health Branch, the City of San Juan
Capistrano, California State Parks and Southern California Edison
FIGURE 2- Real Time Radiation Monitor Locations
Three Locations around ISIS!:
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61147.01100\32486285.3 1 5