IR 05000361/2023001

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NRC Inspection Report 050-00361/2023-001 and 050-00362/2023-001
ML23046A379
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 02/22/2023
From: Greg Warnick
NRC/RGN-IV/DRSS/DIOR
To: Bauder D
Southern California Edison Co
References
IR 2023001
Download: ML23046A379 (15)


Text

February 22, 2023

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2023-001 AND 050-00362/2023-001

Dear Doug Bauder:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on January 23-26, 2023, at the San Onofre Nuclear Generating Station, Units 2 and 3. 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 licenses. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, performance of independent radiation measurements, and interviews with personnel.

Specifically, the inspectors reviewed decommissioning activities in progress at Units 2 and 3, solid radioactive waste management and transportation of radioactive material, and remedial and final status surveys. The inspectors discussed the results of the inspection with you and members of your staff during the final exit meeting on January 26, 2023. The inspection results are documented in the enclosure to this letter. Within the scope of the inspection, no violations were identified, and no response to this letter is required.

During the onsite inspection, staff from the Oak Ridge Associated Universities, Oak Ridge Institute for Science and Education conducted a confirmatory survey of the two intake structures on behalf of the NRC. The results of the confirmatory survey were not available at the end of the onsite inspection and will be presented to you under separate correspondence.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, the 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 Dr. Robert Evans at 817-200-1234, or the undersigned at 817-200-1249.

Sincerely, Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket Nos. 50-361; 50-362 License Nos. NPF-10; NPF-15 Enclosure:

Inspection Report 050-00361/2023-001; 050-00362/2023-001 w/Attachment: Supplemental Inspection Information Distribution via Listserv Signed by Warnick, Gregory on 02/22/23

ML23046A379 SUNSI Review By: RJE ADAMS:

Yes No Sensitive Non-Sensitive Non-Publicly Available Publicly Available Keyword NRC-002 OFFICE DRSS/DIOR NMSS/DUWP/URMDB C:DIOR NAME RJEvans LMGersey GGWarnick SIGNATURE

/RA/

/RA/

/RA/

DATE 02/16/23 02/16/23 02/22/23

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.

050-00361; 050-00362 License Nos.

NPF-10; NPF-15 Report Nos.

050-00361/2023-001; 050-00362/2023-001 Licensee:

Southern California Edison Company Facility:

San Onofre Nuclear Generating Station, Units 2 and 3 Location:

5000 South Pacific Coast Highway San Clemente, California Dates:

January 23-26, 2023 Inspectors:

Robert J. Evans, PhD, CHP, PE, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Linda M. Gersey, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Accompanied By:

Troy Johnson, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Eric McManus, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Approved By:

Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Attachment:

Supplemental Inspection Information

EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 05000361/2023-001; 05000362/2023-001 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 (SONGS), Units 2 and 3. In summary, the licensee and its decommissioning contractor were conducting activities in accordance with site procedures, license requirements, and applicable NRC regulations.

Decommissioning Performance and Status Review at Permanently Shutdown Reactors

The licensee and its decommissioning contractor were conducting decommissioning activities in accordance with the instructions provided in the Post Shutdown Decommissioning Activities Report and site procedures. Radiological controls and related postings were being maintained. (Section 1.2)

Solid Radioactive Waste Management and Transportation of Radioactive Materials

The licensees decommissioning contractor was conducting reactor vessel internal segmentation work involving greater-than-Class C material in accordance with approved work plans and liner loading procedures. (Section 2.2.a)

The contractor conducted waste management and transportation activities in accordance with the Post Shutdown Decommissioning Activities Report and site procedures.

(Sections 2.2.b and 2.2.c)

The contractor identified a shipment that contained radioactive contaminated material that was in process to be released from the site. The contractor took prompt corrective actions in response to the event. (Section 2.2.d)

Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors

The licensees contractor designed and conducted remedial action support surveys in accordance with procedural requirements and with NRC guidance documents.

(Section 3.2.a)

The inspectors concluded that the licensee had developed and implemented a final status survey program that was generally consistent with NRC guidance. (Section 3.2.b)

A contractor conducted confirmatory surveys on behalf of the NRC. The results of the confirmatory survey will be presented to the licensee under separate correspondence.

(Section 3.2.c)

Report Details Summary of Plant Status On June 12, 2013, the Southern California Edison Company, the licensee, formally notified the NRC that it had permanently ceased power operations at SONGS, Units 2 and 3, effective June 7, 2013 (Agencywide Documents Access and Management System [ADAMS]

Accession No. ML131640201). By letters dated June 28, 2013 (ML13183A391), and July 22, 2013 (ML13204A304), the licensee informed the NRC that the reactor fuel had been permanently removed from the Units 3 and 2 reactor vessels as of October 5, 2012, and July 18, 2013, respectively. The NRC subsequently issued the permanently defueled technical specifications on July 17, 2015 (ML15139A390), along with revised facility operating licenses to reflect the permanent cessation of operations at SONGS, Units 2 and 3.

As required by Title 10 the Code of Federal Regulations (10 CFR) 50.82(a)(4), the licensee submitted its Post Shutdown Decommissioning Activities Report (PSDAR) to the NRC on September 23, 2014 (ML14269A033). The PSDAR outlines the planned decommissioning activities. The current version of the PSDAR is dated May 7, 2020 (ML20136A339). The licensee chose to implement the decommissioning alternative DECON. DECON is the removal or decontamination of equipment, structures, or portions of the facility and site that contain radioactive contaminants to levels that permit termination of the license.

On December 20, 2016, the licensee announced the selection of AECOM and EnergySolutions as the decommissioning general contractor. The joint venture between the two companies was called SONGS Decommissioning Solutions (SDS). The SDS organization manages most decommissioning activities as described in the PSDAR.

By letter dated August 7, 2020 (ML20227A044), the licensee certified that all spent fuel was removed from both Units 2 and 3. Accordingly, SONGS entered their Independent Spent Fuel Storage Installation (ISFSI) Only Technical Specifications, Emergency Plan, and Security Plan on August 10, 2020. After removal of all spent fuel from the two units, SDS started decommissioning work within the two containment buildings and spent fuel pool (SFP) rooms.

During the inspection week, the activities in progress included segmentation of the reactor vessel internals inside the two containments. The decommissioning contractor was also preparing the two containments for future removal of large components. In addition, the contractor was removing hot spots and conducting remedial activities within the radwaste building, removing the fuel racks from the Unit 2 SFP, and demolishing the Unit 3 turbine building. Finally, the contractor was conducting radiological surveys in the Units 2 and 3 intake structures for future release.

Decommissioning Performance and Status Review at Permanently Shutdown Reactors (Inspection Procedure 71801)

1.1 Inspection Scope The objectives of this portion of the inspection effort were to evaluate the status of decommissioning and to verify whether the licensee was conducting decommissioning and maintenance activities in accordance with regulatory and license requirements.

1.2 Observations and FindingsSection II.A of the PSDAR provides a description of the decommissioning periods. The site is currently in Period 4. Period 4 begins with the completion of fuel transfer operations and extends through the end of the decommissioning and decontamination work. At the time of the inspection, the licensee and its decommissioning general contractor SDS were conducting decommissioning activities in accordance with the general guidance provided in Section II.B.1 of the PSDAR. The inspectors discussed the current schedule with decommissioning management staff and conducted site tours to observe work in progress.

The contractor was actively segmenting the reactor vessel internals in both containments. The vessel internals were being segmented, in part, to separate the greater-than-Class C (GTCC) wastes from the remainder of the material. The GTCC wastes were being loaded into storage liners and will eventually be transferred and stored at the onsite Independent Spent Fuel Storage Installation (ISFSI). The remainder of the vessel internals will be packaged for disposal as radioactive wastes.

At the time of the inspection, there were two reactor vessel internals volume reduction stations in service in each of the two units. In Unit 2, the contractor was actively cutting the upper guide structure fuel alignment plate at one station and the core shroud core plate at the other station. In Unit 3, the contractor was cutting the upper guide structure core plate at one station and the core support barrel D-ring at the other station. The inspectors reviewed the approved work packages for the work in progress and interviewed the staff who were conducting the work. The inspectors concluded that the contractors were conducting the work in accordance with approved procedures.

The inspectors toured the Unit 2 and Unit 3 containments and observed the work in progress. The work included cutting of interferences for future removal of large components and staging of contaminated equipment and radioactive trash for future removal and disposal. Housekeeping was adequate in both containments, and the radiological controls were consistent with regulatory requirements in the two restricted areas.

Section II.B.3 of the PSDAR provides a description of the planned decommissioning and dismantlement activities. Material with contamination below the applicable radiological limits may be released for unrestricted disposition including recycling, while radioactive contaminated material will be packaged and shipped to a low-level waste disposal facility. The Unit 2 turbine building had been essentially demolished prior to the onsite inspection. In addition, the gantry crane on the Unit 3 turbine building was permanently removed from service prior to the onsite inspection. The work in progress during the inspection included demolition of the Unit 3 turbine building. The contractor was separating the metal from the concrete debris for recycling. The concrete was being packaged and disposed as very low-level radioactive waste. During the inspection, the contractor was crushing concrete and loading the crushed material into rail cars for transportation to the disposal site. The inspectors noted that the decommissioning work was being conducted with an emphasis on personnel safety.

The inspectors conducted independent radiological surveys during plant tours using a Radeye G gamma survey meter (serial number 30932, calibrated to cesium-137 with a calibration due date of November 9, 2023). The inspectors validated that the licensee

had properly posted the radiological areas that were toured. No high radiation area was identified that was not already posted and controlled. No radiation areas were identified outside of the radiologically restricted and posted areas.

1.3 Conclusion The licensee and its decommissioning contractor were conducting decommissioning activities in accordance with the instructions provided in the PSDAR and site procedures. Radiological controls and related postings were being maintained.

Solid Radioactive Waste Management and Transportation of Radioactive Material (Inspection Procedure 86750)

2.1 Inspection Scope The purposes of this portion of the inspection were to verify the effectiveness of the licensees and its decommissioning contractors programs for processing, handling, storage, and transportation of radioactive material.

2.2 Observations and Findings a.

Review of GTCC Work in ProgressSection II.B.1 of the PSDAR states that the reactor vessel internals will be removed and segmented as necessary to separate the GTCC wastes. The GTCC wastes will be placed in storage canisters for eventual storage at the onsite ISFSI. The inspectors reviewed the status of the GTCC work.

The contractor developed loading plans for each of the 10 liners, five per unit, that will be filled with GTCC material. The reactor vessel internals were being segmented in accordance with approved cutting plans. The material containing GTCC was segregated from the rest of the material. The liners, when filled, will eventually be packaged in a canister. The 10 canisters will be transferred to the onsite ISFSI for storage.

At the time of the inspection, one liner was located in the Unit 2 reactor cavity, while two liners were located in the Unit 3 reactor cavity. Material containing GTCC wastes was being placed into the liners or staged adjacent to the liners. The contractor plans to start removing liners containing GTCC material from the reactor cavities in March 2023. The inspectors concluded that the licensees contractor was conducting work in accordance with approved segmentation work plans and liner loading procedures.

b.

Review of SFP Rack Removal and Shipment Activities The PSDAR,Section II.B.1, states that one of the major decommissioning activities to be conducted includes removal and disposal of the spent fuel storage racks. The inspectors reviewed the status of the rack removal work from the two SFPs. The Unit 2 pool had been drained to just above the top of the spent fuel racks. The decommissioning contractor had removed, packaged, and shipped the first of six racks. The inspectors reviewed the shipping manifest for the first shipment. The second rack was staged onsite for shipment. The inspectors also observed the movement of the third rack.

The inspectors observed radiation protection surveys and pressure washing of the suspended fuel rack for gross contamination removal. A contractor representative walked the inspectors through the procedure to remove, decontaminate and package fuel racks for shipment. The inspectors observed final packaging and the contractors inspection of the second fuel rack as it was being prepared for subsequent loading onto a shipping trailer. The inspectors reviewed two partially completed work packages for the second and third racks. Based on the work observed and discussion with site staff, the inspectors concluded that the contractor was conducting work in accordance with approved procedures.

After all racks have been removed from the Unit 2 SFP, the contractor plans to start removing the racks from the Unit 3 SFP. Following removal of all racks, the remainder of the pool water from the two pools will be drained, processed, and released in accordance with the Offsite Dose Calculation Manual.

c.

Review of Shipment Activities During routine tours, the inspectors observed the status of radioactive material containers and area postings. Outside of the Unit 2 containment building, the inspectors observed the removal of the impact limiters from a waste container that was staged on a trailer. The trailer had recently arrived at the site. The inspectors noted that the work supervisor demonstrated an understanding of the work procedure with an intent to perform the required radiological surveys upon removal of the impact limiter components.

The inspectors also validated that staged rail cars were marked and labeled as empty containers, in accordance with the U.S. Department of Transportation regulations. The inspectors observed operations during loading of a rail car with crushed concrete material from the Unit 2 turbine generator building demolition. The contractor controlled all crushed concrete as radioactive material in accordance with site procedures. The inspectors observed the safe control of the area while heavy equipment was in use, and the inspectors validated that the labels and postings were correctly updated after the crushed concrete was loaded into car.

The inspectors also observed the operation of the truck/trailer monitoring station prior to allowing vehicle entry into the sites controlled area. Discussions with the radiation protection technician validated his understanding of the operating procedures and knowledge of actions required in the event of either a valid or false monitoring alarm.

d.

Review of Recent Incident involving Contaminated Wastes The inspectors reviewed a recent incident in which radioactive material was identified in a shipment being released from the site. Site procedures specify that prior to shipment of demolition debris, an aggregate check of the shipment using a radiological survey instrument must be performed and an evaluation of the load must also be performed using the truck monitor at the site exit. Material and equipment shall not be released from radiological controls if they are contaminated with plant-related radioactive material that is distinguishable from background. This two-step survey process was implemented, in part, to help prevent the accidental release of contaminated material.

In mid-December 2022, during a routine survey of a truck load of scrap material preparing for release, an aggregate radiological check of the load identified radioactive material that was distinguishable from background. The truck returned to the restricted area for offloading, and radioactive contaminated piping was identified in the load. The piping was determined to be radwaste discharge piping that was improperly marked. The remaining debris piles were scanned for radioactivity and the recovered piping was properly dispositioned as radioactive material.

In summary, the contractors procedural control and field survey of radioactive material was effective in that it successfully identified contaminated piping in a shipment that was prepared to leave the site. The contractor took appropriate corrective actions including issuance of a condition report (SDS-001547) to determine the causes of the incident and formulation of steps necessary to prevent recurrence of the event.

2.3 Conclusion The licensees decommissioning contractor was conducting reactor vessel internal segmentation work involving GTCC material in accordance with approved work plans and liner loading procedures. The contractor conducted waste management and transportation activities in accordance with the PSDAR and site procedures. The contractor identified a shipment that contained radioactive contaminated material that was in process to be released from the site. The contractor took prompt corrective actions in response to the event.

Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors (Inspection Procedure 83801)

3.1 Inspection Scope To verify that the licensee has decontaminated the Units 2 and 3 intake structures to acceptable residual radioactivity levels for unrestricted use, as specified in Subpart E, Radiological Criteria for License Termination, to 10 CFR Part 20, Standards for Protection Against Radiation.

To verify that the licensees implementing procedures, radiological measurements, decommissioning surveys, and documentation of decommissioning surveys for the Unit 2 and 3 intake structures comply with approved site procedures.

To verify the NRCs contractor performs final status surveys (FSS) in the Unit 2 and 3 intake structures, in accordance with the approved project-specific plan, to ensure that the licensees decommissioning activities and survey program in these areas have been implemented in a manner that provides confidence in the results that the site does not pose an undue risk to public health and safety.

3.2 Observations and Findings a.

Review of Remedial Action Support Survey Program The licensee and its decommissioning contractor plan to survey and release the Units 2 and 3 intake structures for backfilling. At the time of the inspection, the licensee had not submitted its License Termination Plan which would include the proposed release

criteria for the intake structure surfaces. Although the License Termination Plan has not been submitted, the contractor had developed proposed release criteria and submitted the proposed criteria to the NRC for review and acceptance. The contractor also developed procedures for remedial action support surveys (RASS). Although the contractor was conducting some of the work at risk, without an approved License Termination Plan, the NRC compared the contractors efforts against the guidance provided in NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), and NUREG-1757, Consolidated Decommissioning Guidance, volumes 1-3, which provide instructions for development of survey plans and methodologies.

The inspectors reviewed the performance of the RASS in the Units 2 and 3 intake structures. Procedures, chain of custody, survey data collection, data management, survey quality assurance requirements, and records retention requirements were inspected. A selection of RASS survey data with a focus on risk significance was reviewed for compliance and adequacy by the inspectors. The contractors radiological engineers were interviewed as to the methodology and execution of RASS surveys as well as to explain select survey results reviewed by the inspectors.

The inspectors observed survey performance and interviewed select technicians performing RASS surveys in a Class 2 survey unit in the Unit 2 intake structure. All instruments in use were calibrated, used in accordance with procedures, and were of the appropriate type to measure the radionuclides of concern. Instruments in use included the Ludlum 2350-1 with 44-10, 43-68, and 43-37 detectors as appropriate to the radionuclides of concern. All technicians observed by the inspectors were appropriately trained for the instruments they were operating, and their training was verified current.

In summary, the contractor designed and conducted RASS surveys in accordance with procedural requirements and with NRC guidance documents.

b.

Review of Final Status Surveys When the reactors were in operation, the underground intake structures provided cooling water to the turbine condensers and provided dilution for effluent releases. Both Unit 2 and Unit 3 have separate intake structures that are mirror images of each other. Due to the small footprint of the owner-controlled area, the licensee needs to release the intake structures for unrestricted use and to backfill the structures to support future decommissioning of the remainder of the radioactive contaminated power block.

To support the release and survey of the intake structures, the licensees decommissioning contractor removed the sludge-type sediment and scraped and power-washed the surfaces in both intake structures. Following cleaning, the contractor plans to conduct, or has conducted, RASS and FSS as needed to support the release of the structures.

Once the FSS results indicate the intake structures meet the unconditional release criteria specified in site procedures, the licensee plans to backfill the intake structures with a flowable concrete fill from the -26 feet (-26) to the 7 elevation in both intake structures. The backfilled area will remain in place after license termination.

To dewater the Unit 2 intake structure, a grout bag was permanently placed on the return side to isolate the Pacific Ocean from the structure while accommodating continued use of the saltwater dilution pumps. Two gates were installed in the Unit 2 intake side to isolate the remaining Unit 2 area. The Unit 3 side was isolated from the Pacific Ocean by installing a stop gate on the return side and 2 gates on the intake side.

The licensee determined the boundary of intake structure survey units as the concrete that extends from the 7 elevation down to -26, and structures that accommodated gates 4 and 6. The historical site assessment and initial sampling results found contaminants to only be in the sediments which if present, would only be in the floor areas where the sediments had settled. A potential area of interest is the outfall vent shaft area between the outfall weir and gate 1, where the radwaste effluent lines entered and discharged into the outfalls of both units. Sediments/seafoam around the Unit 2 vent shaft at the 30 level has also shown prior contamination. With the sediments removed, no individual measurement is expected to exceed the contractors proposed estimated derived concentration guideline level (eDCGL). Thus, the -13 and the -26 floor surfaces and conjoined wall surfaces up to 1 meter for both units was classified as a Class 2 survey Unit, along with the area between the outfall weir and gate 1 to the ceiling. The remaining areas were classified as Class 3 survey units as these areas were not expected to contain any residual activity. Due to the size of the areas to be surveyed, the licensee determined that a minimum of two Class 2 survey units and one Class 3 survey unit will be required for each intake structure.

Using the guidance provided in MARSSIM, the licensee determined that a minimum of 14 systematic sample locations are required for each Class 2 survey unit, and 14 random sample locations are required for each Class 3 survey unit. Sample locations were plotted on a map of the intake structures and then clearly marked on the areas inside the intake structures. For each sample location, a concrete sample was collected, a wipe sample is taken, and a static beta/gamma measurement is taken.

The licensee used scan measurements to identify if any small areas of elevated radioactivity were present. In the Class 2 survey units, scanning surveys were designed to detect small areas of elevated activity that were not detected by measurements using the systematic pattern. For the Class 3 survey units, judgmental surface scans were performed on areas with the highest potential for residual contamination based on professional judgement. The licensees survey plan required a minimum of 25% scan surveys of Class 2 survey units, and a minimum of 10% scan surveys in the Class 3 survey units. Scans were conducted using the in-situ object counting system, followed by direct beta measurements and smears. The licensee had sufficient field instrumentation, which were appropriately calibrated, available to perform the necessary scan surveys.

In addition, concrete samples, obtained by core drilling, were collected at all systematic and random sample locations. Concrete samples were sent off-site to a third-party laboratory for volumetric analysis. Samples were collected and processed in accordance with procedures SDS-LT1-PCD-1005, Sample Media Collection for Site Characterization and Final Status Survey, and SDS-LT1-PCD-1006, Sample Media Preparation for Site Characterization and Final Status Survey.

The licenses survey plan identified an investigational process where elevated areas are identified and investigated. This included any areas identified by the surveyor during

real-time scanning and any surface concrete sample exceeding the sum of fractions, using the eDCGLs. Quality control scans and samples were performed on 10% of the sample locations in each survey unit. The target minimum detectable concentration for laboratory analysis of samples was between 10%-50% of the radionuclides eDCGL.

In summary, the inspectors concluded that the licensee had developed and implemented a FSS program that was generally consistent with NRC guidance.

c.

Verification and Confirmatory Surveys Per MARSSIM, a confirmatory survey is used to provide data to substantiate the results of the licensees final status survey. Confirmatory survey activities are limited in scope to spot-checking conditions at selected locations, comparing findings with those of the final status survey, and performing independent statistical evaluations of the data developed from the confirmatory survey with the final status survey. The goal is to conduct a sufficient survey so that the NRC can conclude that the licensees FSS program was implemented in a manner that provides confidence in the licensees results.

The inspectors observed the NRCs contractor, Oak Ridge Associated Universities, Oak Ridge Institute for Science and Education (ORISE), conducted confirmatory surveys in the two intake structures. The implementation of the confirmatory surveys will assist the NRC with the assessment of the licensees FSS design, implementation, and results for demonstrating compliance with the release criteria for the intake structures. The staff from ORISE used an NRC-approved specific project plan for the confirmatory surveys.

Surface scans were conducted for gamma radiation using a Ludlum model 44-10 sodium iodide scintillation detector. Alpha/beta surface scans were conducted using a Ludlum model 43-37 gas-flow proportional counter. Confirmatory scan density was 100% scan coverage on the floors and lower 1 meter of walls. Two volumetric core samples were collected from the Unit 2 discharge area upper walls and one volumetric sample taken from the west wall in Unit 3, areas identified by ORISE as having elevated alpha-plus-beta results. The results of the core samples will be communicated to the licensee under separate correspondence.

3.3 Conclusion The licensees contractor designed and conducted RASS surveys in accordance with procedural requirements and with NRC guidance documents. The inspectors concluded that the licensee had developed and implemented a FSS program that was generally consistent with NRC guidance. A contractor conducted confirmatory surveys on behalf of the NRC. The results of the confirmatory survey will be presented to the licensee under separate correspondence.

Exit Meeting Summary On January 26, 2023, the inspectors presented the final inspection results to the 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 except for certain SDS procedures and documents which were marked as proprietary.

Attachment SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee and Contractor Personnel A. Bates, SCE, Regulatory Affairs Manager D. Bauder, SCE, Chief Nuclear Officer and Vice President Decommissioning V. Bilovsky, SCE, Decommissioning Project Director J. Carey, SCE, Corrective Action Program Manager R. Corbett, SDS, Radiation Protection Manager J. Janke, SCE, ISFSI Manager R. Kalman, SDS, Executive Sponsor C. Ladd, San Diego Gas & Electric J. Madigan, SCE, Nuclear Oversight and Safety Culture Manager S. Mannon, SDS, Regulatory Affairs Manager M. Morgan, SCE, Licensing Engineer R. Quam, SCE, Security Manager R. Pontes, SCE, Environmental/Waste & Radiation Protection General Manager L. Rafner, SCE, Regulatory Affairs D. Randall, SDS, LT/FSS Manager S. Scholler, SDS, LT/FSS Project Manager S. Sewell, SCE, Radiation Protection and Waste Manager 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 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Discussed None Closed None

LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations eDCGL estimated derived concentration guideline level FSS final status survey GTCC greater-than-Class C ISFSI Independent Spent Fuel Storage Installation MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual NRC Nuclear Regulatory Commission PSDAR Post Shutdown Decommissioning Activities Report RASS remedial action support survey SDS SONGS Decommissioning Solutions SFP spent fuel pool SONGS San Onofre Nuclear Generating Station