IR 05000361/2021001
| ML21062A152 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/03/2021 |
| From: | Greg Warnick Division of Nuclear Materials Safety IV |
| To: | Bauder D Southern California Edison Co |
| References | |
| IR 2021001 | |
| Download: ML21062A152 (14) | |
Text
March 3, 2021
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 05000361/2021-001 AND 05000362/2021-001
Dear Mr. Bauder:
This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) inspection conducted on February 8-11, 2021, at the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. The NRC inspectors discussed the results of this inspection with you and members of your staff during a final exit meeting conducted on February 11, 2021. The inspection results are documented in the enclosure to this letter.
This inspection examined activities conducted under your license as they relate to public health and safety, the common defense and security, and to confirm compliance with the Commissions rules and regulations, and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of site meetings, performance of independent radiation measurements, and interviews with personnel. Specifically, the inspectors reviewed decommissioning planning activities for SONGS Units 2 and 3, solid radioactive waste management and transportation program, and the implementation of your fire protection program. Within the scope of the inspection, no violations were identified and a response to this letter is not required.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction. If you have any questions regarding this inspection report, please contact Ms. Stephanie Anderson at 817-200-1213, or the undersigned at 817-200-1249.
Sincerely, Gregory G. Warnick, Chief Reactor Inspection Branch Division of Nuclear Materials Safety
Docket Nos. 50-361; 50-362 License Nos. NPF-10; NPF-15
Enclosure:
Inspection Report 05000361/2021-001; 05000362/2021-001
REGION IV==
Docket Numbers:
05000361; 05000362
License Numbers:
Report Numbers:
05000361/2021-001; 05000362/2021-001
Licensee:
Southern California Edison Company
Facility:
San Onofre Nuclear Generating Station, Units 2 and 3
Location:
5000 South Pacific Coast Highway San Clemente, California
Inspection Dates:
February 8-11, 2021
Inspectors:
Stephanie G. Anderson Senior Health Physicist Reactor Inspection Branch Division of Nuclear Materials Safety
Linda M. Gersey Health Physicist Materials Licensing and Decommissioning Branch Division of Nuclear Materials Safety
Approved By:
Gregory G. Warnick, Chief Reactor Inspection Branch Division of Nuclear Materials Safety
EXECUTIVE SUMMARY
San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 05000361/2021-001; 05000362/2021-001
This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at the San Onofre Nuclear Generating Station, Units 2 and 3. In summary, the licensee was conducting these activities in accordance with site procedures, license requirements, and applicable NRC regulations.
Within the scope of the inspection, no violations were identified.
Decommissioning Performance and Status Review at Permanently Shutdown Reactors
- The licensee was implementing the decommissioning activities in accordance with the regulations and license requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility. (Section 1.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials
- The inspectors concluded that the licensee and its contractors were knowledgeable of the transportation requirements and adequately trained to implement the program.
The licensee maintained a solid radioactive waste management and transportation program that met regulatory requirements. The licensee was granted an exemption from 10 CFR Part 20, Appendix G, Section III.E., that extends the receipt acknowledgment period for radioactive waste shipments from 20 days to 45 days. (Section 2.2)
Fire Protection Program at Permanently Shutdown Reactors
- The licensee was effectively implementing the fire protection program in compliance with regulatory requirements. The inspectors conducted walkdowns of plant areas and observed control of combustible materials, housekeeping, and ignition sources.
(Section 3.2)
Report Details Summary of Plant Status On June 12, 2013, the Southern California Edison Company (SCE), the licensee, formally notified the NRC by letter that it had permanently ceased power operations at the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, effective June 7, 2013. The licensees letter is available in the Agencywide Documents Access and Management System (ADAMS)
under (ADAMS Accession No. ML131640201). By letters dated June 28, 2013 (ADAMS Accession No. ML13183A391), and July 22, 2013 (ADAMS Accession No. ML13204A304), the licensee informed the NRC that the reactor fuel had been permanently removed from SONGS, Units 3 and 2, reactor vessels as of October 5, 2012, and July 18, 2013, respectively.
Upon docketing of these certifications, and pursuant to Title 10 of the Code of Federal Regulations (CFR) 50.82(a)(2), the SONGS, Units 2 and 3, facility operating licenses no longer authorized operation of the reactors or emplacement or retention of fuel into the reactor vessels.
In response to the licensees amendment request, the NRC issued the permanently defueled technical specifications on July 17, 2015 (ADAMS Accession No. ML15139A390), along with revised facility operating licenses to reflect the permanent cessation of operations at SONGS, Units 2 and 3.
The licensee submitted its Post-Shutdown Decommissioning Activities Report (PSDAR) on September 23, 2014 (ADAMS Accession No. ML14269A033), which is required to be submitted within 2 years following permanent cessation of operations under 10 CFR 50.82(a)(4). The PSDAR outlines the decommissioning activities for SONGS, Units 2 and 3. By letter dated August 20, 2015 (ADAMS Accession No. ML15204A383), the NRC informed the licensee that the PSDAR contained the information required by 10 CFR 50.82(a)(4)(i). The current version of the PSDAR is dated May 7, 2020 (ADAMS Accession No. ML20136A339).
The licensee submitted a license amendment request dated December 15, 2016 (ADAMS Accession No. ML16355A015), to revise the Permanently Defueled Emergency Plan into an Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP), and to revise the emergency action level (EAL) scheme into ISFSI-Only EALs for SONGS, Units 1, 2, and 3 ISFSI. The proposed changes reflect the new status of the facility, as well as the reduced scope of potential radiological accidents, since all of the spent fuel has been moved to dry cask storage within the onsite ISFSI.
The NRC issued amendments to the SONGS operating licenses to allow transition to an IOEP and EAL scheme on November 30, 2017 (ADAMS Accession No. ML17310B482). The NRC inspectors determined that the SONGS IOEP and associated changes provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at the SONGS facility. The changes were reviewed, and appropriate conforming changes were properly addressed in the applicable revision and sections of the SONGS Updated Final Safety Analysis Report.
License Amendment 169 (Unit 1), 237 (Unit 2), and 230 (Unit 3) were submitted on December 15, 2016, (ADAMS Accession No. ML16355A014) and approved by the NRC by letter dated January 9, 2018 (ADAMS Accession No. ML17345A657). These license
amendments changed the operating licenses and technical specifications to reflect the removal of all spent nuclear fuel from the SONGS, Units 2 and 3 Spent Fuel Pools (SFPs) and its
transfer to dry cask storage within an onsite ISFSI. These changes fully reflect the permanently shutdown status of the decommissioning facility, as well as the reduced scope of structures, systems, and components necessary to ensure plant safety since all spent fuel has been moved to the SONGS ISFSI.
The changes also made conforming revisions to the SONGS, Unit 1 technical specifications and combined them with the SONGS, Units 2 and 3 technical specifications. This license amendment became effective as of the date the licensee submitted a written notification to the NRC that all spent nuclear fuel assemblies had been transferred out of the SONGS SFPs and placed in storage within the onsite ISFSI. In a letter to the NRC dated August 7, 2020, (ADAMS Accession No. ML20227A044) the licensee has certified that all spent fuel has been removed from the SFPs of Units 2 and 3. Accordingly, SONGS entered their ISFSI-Only Technical Specifications, Emergency Plan (EP), and Security Plan on August 10, 2020.
On December 20, 2016, the licensee announced the selection of AECOM and EnergySolutions as the decommissioning general contractor for SONGS. The joint venture between the two companies is called SONGS Decommissioning Solutions (SDS). The SDS organization manages the decommissioning activities as the decommissioning general contractor, which is described in the licensees PSDAR.
The California Environmental Quality Act is the state equivalent of the Federal National Environmental Policy Act. For SONGS, the California State Lands Commission (CSLC)
performed the California Environmental Quality Act review, which was triggered by the need to establish the final disposition for the offshore conduits that are under a CSLC lease. On February 11, 2019, the Final Environmental Impact Report was released by the CSLC. The CSLC held a public meeting on March 21, 2019, to consider the Final Environmental Impact Report and a lease application to decommission the offshore infrastructure associated with SONGS, Units 2 and 3. On October 17, 2019, the California Coastal Commission approved, with conditions, the Coastal Development Permit to begin decontamination and dismantlement of the above grade structures at SONGS, which authorized active decommissioning activities at the site. Now that all spent fuel has been removed from the SFPs to the ISFSI, SDS has begun active decommissioning of the site.
Decommissioning Performance and Status Review at Permanently Shutdown Reactors (71801)
1.1 Inspection Scope The inspectors reviewed documents, interviewed plant personnel, and conducted site tours to assess the licensees performance in the following areas:
Status of decommissioning and verify whether the licensee is conducting decommissioning and maintenance activities in accordance with regulatory and license requirements;
Licensee awareness of work activities to assess their control and conduct of decommissioning;
Status of the licensees decommissioning staffing, personnel qualifications, and training requirements, including that of the contracted workforce, to ensure that license requirements are met, as applicable to the current decommissioning status;
- Progress and changes that potentially impact decommissioning financial assurance, to supplement information for the Financial Assurance Branch to support and ensure a thorough financial analysis review of the annual decommissioning trust fund reported by the licensee;
Whether the licensee is identifying problems related to decommissioning and maintenance activities at an appropriate threshold and entering them into the corrective action program;
Performed plant tours to assess field conditions and decommissioning activities; and
Observed and assessed the status of facility housekeeping.
1.2 Observations and Findings The PSDAR provides the general dates for each decommissioning phase implementation period and associated activities for that period. The licensee stated that the implementation of the activities described under each period may overlap and not necessarily be implemented consecutively. Currently the site has entered Period 4, D&D (Decontamination and Dismantlement) Dry Storage, which began with the completion of fuel transfer and extends through the completion of D&D work.
The inspectors attended meetings that included discussion of decommissioning activities as well as the current plant status for each day. The meetings provided participants with useful information about the daily status of plant activities. The inspectors performed tours of the facilities, command center, Unit 2 and Unit 3 containment buildings, and along the west road of the plant. Plant staff appeared to be knowledgeable of site conditions and based on observations, the inspectors determined that the licensee was adequately maintaining the material condition of the facilities, as well as the structures, systems, and components that are necessary for safe decommissioning. General observations by the inspectors identified good housekeeping practices, and appropriate radiological postings and labeling. The inspectors did not identify any radiation area that was not adequately identified and posted by the licensee.
The licensees decommissioning contractor, SDS, is currently preparing the Unit 2 and Unit 3 containment buildings for the reactor vessel internals segmentation project. This includes making modifications inside the containment buildings, including removal of the safety injection tanks and removal of all interferences to bring the reactor vessel internals segmentation equipment into the containments. The inspectors toured the Unit 2 and Unit 3 containment buildings and evaluated whether site personnel were focusing on safety, adherence to procedures, and radiological precautions as directed by regulatory and procedural requirements.
The inspectors interviewed various SCE and SDS staff and verified that the licensee has appropriately identified and stored, in accordance with quality assurance requirements, records important to decommissioning as defined in 10 CFR 50.75(g).
The inspectors evaluated the licensees decommissioning cost planning and assessment, which are an important part of the decommissioning process. The inspectors determined that the licensees cost planning and assessment were inclusive of current and planned major decommissioning activities as identified in the PSDAR.
The inspectors also determined that licensee funding and expenditures were tracking as planned by the licensee with no significant deviations to expenditures up to current date nor major deviations from the decommissioning schedule.
1.3 Conclusion The licensee was implementing the decommissioning activities in accordance with the regulations and license requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility.
Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750)
2.1 Inspection Scope The inspectors reviewed documents and interviewed plant personnel to assess the licensees performance in the following areas:
Whether the licensee provided detailed instructions and operating procedures for transfer, packaging, and transport of low-level radioactive waste;
Whether the material was properly classified, described, packaged, marked, and labeled for transportation;
Effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material;
Whether the licensee is identifying problems related to radioactive waste storage, processing, and transportation activities at an appropriate threshold and entering them into the corrective action program;
Whether the licensee used updated and audited procedures when scaling factors or correlation factors were used to quantify the concentration of hard-to-detect radionuclides; and
Whether shipments made by the licensee were in compliance with NRC and Department of Transportation regulations.
2.2 Observations and Findings The inspectors reviewed the licensees waste management program, which is implemented by SDS using procedure SDS-WM1-PGM-0001, Waste Management Program, Revision 13. During 2020, SDS made a total of 39 low-level and mixed radioactive waste shipments by truck and rail. Mixed waste consisted of radioactive contaminated asbestos. At the time of this inspection, a total of three waste shipments consisting of concrete, all transported by rail, had been made since January 2021. One rail car is manifested as one shipment, and each rail car can hold up to four containers of various types. Only Class A radioactive waste, as defined in 10 CFR Part 61.55, is being shipped for disposal and will be for the foreseeable future.
The first rail shipment was initiated on September 29, 2020, with four intermodals of
radioactive asbestos, contained in one rail car, manifested to the EnergySolutions'
Clive Disposal facility in Clive, Utah. Due to the recent changes in railway companies servicing the licensees rail spur, the shipment did not leave the site until October 8, 2020, and arrived at the Clive facility on October 23, 2020, for a total transit duration of 24 days. Transit time begins the day the waste is manifested and ends when the shipments arrival is acknowledged by the disposal facility. The requirement in 10 CFR Part 20, Appendix G, Requirements for Transfers of Low-Level Radioactive Waste Intended for Disposal at Licensed Land Disposal Facilities and Manifests,Section III.E, states, in part, that if the shipper has not received notification from the waste disposal site that the waste was received within 20 days of manifest, that the licensee shall conduct an investigation to include tracing the shipment and provide a written report to the NRC. To ensure compliance, the location of the shipment was monitored using global positioning satellite, and the licensee and EnergySolutions, LLC received daily tracking reports of the waste shipment from the railway until its receipt.
At no time was the shipment lost or at an unknown location. By letter dated November 3, 2020, the licensee notified the NRC of their investigation into the causes of the exceedance of the 20-day receipt notification (ADAMS Accession No. ML20318A087).
The licensee acknowledged the uncertainty of timing of shipments by rail transport due to circumstances beyond their control and by letter dated September 1, 2020, (ADAMS Accession No. ML20255A083), requested an exemption from 10 CFR Part 20, Appendix G, Section III.E., for investigating, tracing, and reporting shipments of low-level radioactive wastes where receipt is not acknowledged by the recipient within 20 days after transfer to the shipper. The NRC granted the exemption request by letter dated November 13, 2020, that extends the receipt acknowledgment period from 20 days to 45 days (ADAMS Accession Package No. ML20287A353). At the time of this inspection, no other radioactive shipment has exceeded the 20-day transport time to the disposal facility.
Future shipments are estimated by reviewing future time-tables of work projects provided by the licensee. SDS representatives stated they anticipate an increase up to 10 shipments per week beginning the third quarter of 2021, and up to 20 shipments per week by the end of 2021. Both SDS and SCE officials acknowledged that additional staff and other resources will be needed due to the increase of shipments and both companies were in the process of hiring additional personnel.
As of January 2021, two types of radioactive waste streams were being generated by the current decommissioning of the facility. These include concrete from the equipment hatch for containment and metal from Units 2 and 3 Containments. The licensee stated that all concrete will be disposed of as radioactive waste regardless of actual contamination being present. One non-radioactive waste stream consisting of junk metal, demolition debris, and scrap metal was being segregated and surveyed for unrestricted release. The licensee is not authorized to process radioactive waste on site, except for rubbling concrete and cutting material to fit into disposal containers. SDS observes demolition activities to ensure segregation of materials is adequately performed.
Based on discussions with responsible staff and review of representative records, the inspectors concluded that the shippers were knowledgeable of the regulations, had adequate training, and demonstrated adequate skills to accomplish the package
preparation requirements for public transport.
2.3 Conclusion The inspectors concluded that the licensee and its contractors were knowledgeable of the transportation requirements and adequately trained to implement the program. The licensee maintained a solid radioactive waste management and transportation program that met regulatory requirements. The licensee was granted an exemption from 10 CFR Part 20, Appendix G, Section III.E., that extends the receipt acknowledgment period for radioactive waste shipments from 20 days to 45 days.
Fire Protection Program at Permanently Shutdown Reactors (64704)
3.1 Inspection Scope The inspectors reviewed documents and interviewed plant personnel to assess the licensees performance in the following areas:
Assess whether the licensee has an effective decommissioning fire protection program that is maintained and implemented to address the potential for fires that could result in the release or spread of radioactive materials;
Verify in the absence of spent fuel in the spent fuel storage pool the decommissioning fire protection program ensures adequate protection from the fire-induced release of radioactive material from contaminated plant areas and combustible waste products; and
Performed plant tours to assess field conditions and the storage of combustible materials.
3.2 Observations and Findings Title 10 CFR 50.48(f) states, in part, that the licensee shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials onsite or result in a localized radiological hazard. The inspectors reviewed the licensees fire protection program for compliance with regulatory and license requirements. The inspectors reviewed the fire protection program as defined by procedures SDS-FP1-PGM-0001, SDS Fire Protection Program, Revision 7, and ENG-16, Fire Protection Program, Revision 1.
Regulatory Guide 1.191, Fire Protection Program for Nuclear Power Plants During Decommissioning and Permanent Shutdown, describes the methods acceptable to the NRC for complying with the NRCs regulations for fire protection programs for licensees in decommissioning. This regulatory guide is referenced in the licensees implementing procedures, and the inspectors compared the licensees fire protection program to the guidance provided in the regulatory guide.
The licensees fire protection program records included a detailed fire hazards analysis.
This document provided an analysis of the various plant areas and the fire protection requirements for those areas. The licensee fire protection program procedures described the staff responsibilities, program elements, and records requirements. In addition, procedures were developed to implement the various program attributes such
as system operations, maintenance, design control, staffing, and training.
According to 10 CFR 50.48(f), the objectives of the fire protection program are to:
(1) reasonably prevent fires that could result in a radiological hazard from occurring; (2) rapidly detect, control, and extinguish those fires that do occur; and (3) ensure that the risk of fire-induced radiological hazards to the public, environment and plant personnel is minimized. The inspectors compared the licensees fire protection program against the objectives provided in the regulations.
To prevent fires from occurring, the licensee established and implemented administrative procedures for fire prevention control of transient combustible material and control of ignition sources. The inspectors conducted site tours to confirm that the procedure controls were being implemented. In particular, the inspectors toured the fire areas in the Unit 2 and Unit 3 containment building. The inspectors concluded that the licensee was effectively controlling combustible materials around ignition sources and impairments in these areas in accordance with procedure requirements.
The inspectors reviewed the licensees ability to rapidly detect, control, and extinguish fires. Fire suppression systems were in service to include automatic sprinkler systems and fire extinguishers located throughout the plant. The inspectors also reviewed the fire brigade staffing requirements, training records, and the memorandum of understanding with the offsite fire brigade. All staff training requirements were completed satisfactorily.
3.3 Conclusion The licensee was effectively implementing the fire protection program in compliance with regulatory requirements. The inspectors conducted walkdowns of plant areas and observed control of combustible materials, housekeeping, and ignition sources.
Exit Meeting Summary On February 11, 2021, the NRC inspectors presented the final inspection results to Mr. Doug Bauder, Chief Nuclear Officer and Vice President Decommissioning, and other members of the licensees staff. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified with the exception of all SDS procedures and documents reviewed during the inspection, which were marked as proprietary.
SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee Personnel A. Bates, SCE, Regulatory Affairs and Oversight Manager S. Mannon, SDS, Regulatory Affairs Manager L. Rafner, SCE, Regulatory Affairs M. Morgan, SCE, Regulatory Affairs J. McGaw, SCE, Regulatory Affairs J. Sophie, SDS, Containment Systems Removal Project Manager R. Kalman, SDS, Operations Project Director B. Fraser, SDS, Senior Vice President B. Quinn, SDS, D&D Director R. Benson, SDS, Fire Protection Engineer W. Richter, SDS, Fire Marshall D. Arai, SCE, Senior Nuclear Engineering A. Woods, SDS, Waste Manager L. Villalobos, SDS, Certified Broker J. Wagner, SDS, Waste Package Certifier C. Cates, SCE, Prudency Senior Project Manager R. Besich, SCE, Chief Financial Officer
INSPECTION PROCEDURES USED
IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 64704 Fire Protection Program at Permanently Shutdown Reactors
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed None
Discussed None
LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations CSLC California State Lands Commission D&D Decontamination and Dismantlement EAL Emergency Action Level EP Emergency Plan IOEP ISFSI-Only Emergency Plan ISFSI Independent Spent Fuel Storage Installation NRC Nuclear Regulatory Commission PSDAR Post-Shutdown Decommissioning Activities Report SCE Southern California Edison Company SDS SONGS Decommissioning Solutions SONGS San Onofre Nuclear Generating Station