IR 05000361/2023005
| ML23283A298 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/11/2023 |
| From: | Greg Warnick NRC/RGN-IV/DRSS/DIOR |
| To: | Bauder D Southern California Edison Co |
| Evans R | |
| References | |
| IR 2023005 | |
| Download: ML23283A298 (12) | |
Text
October 11, 2023
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2023-005 AND 050-00362/2023-005
Dear Doug Bauder:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on September 11-14, 2023, at the San Onofre Nuclear Generating Station, Units 2 and 3. The inspectors discussed the results of the inspection with you and members of your staff during the exit meeting on September 14, 2023. 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 licenses. Within these areas, the inspection consisted of selected examination of procedures and representative records, observation of activities, measurement of radiation levels, and interviews with personnel. Specifically, the inspectors reviewed your implementation of decommissioning activities at Units 2 and 3, and your implementation of the radioactive waste treatment and effluent and environmental monitoring programs. Within the scope of the inspection, no violations were identified, and no response to this letter is 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 Dr. Robert Evans at 817-200-1234, or the undersigned at 817-200-1249.
Sincerely, Signed by Warnick, Gregory on 10/11/23 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 050-00361/2023-005; 050-00362/2023-005 w/Attachment: Supplemental Inspection Information Distribution via Listserv
ML23283A298 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: RJE Yes No Non-Sensitive Publicly Available NRC-002 OFFICE DRSS/DIOR DRSS/DIOR C:DIOR NAME REvans MLaFranzo GWarnick SIGNATURE /RA/ /RA/ /RA/
DATE 10/11/23 10/10/23 10/11/23
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos. 050-00361; 050-00362 License Nos. NPF-10; NPF-15 Report Nos. 050-00361/2023-005; 050-00362/2023-005 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: September 11-14, 2023 Inspectors: Robert J. Evans, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Michael M. LaFranzo, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Accompanied by: Christian R. Dennes, 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 Enclosure
EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 05000361/2023-005; 05000362/2023-005 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. In summary, the licensee and its decommissioning contractor were found to be 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 in accordance with the instructions provided in site procedures and commitments provided in the Post Shutdown Decommissioning Activities Report. (Section 1.2)
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
- The NRC reviewed the licensees: (1) environmental monitoring equipment and observed implementation of sampling procedures; (2) Groundwater Protection Initiative program; and (3) liquid effluent storage and treatment system. The inspectors did not identify any significant deficiencies or violations of NRC requirements. (Section 2.2)
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). 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 licensees 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 named 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 had been 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, decommissioning activities in progress included continued segmentation of the reactor vessel internals. The decommissioning contractor was also:
(1) preparing for the removal of the reactor coolant pump motors; (2) removing restraints and interferences for future removal of large components from the two containments; (3) cutting the Unit 3 bio-shield wall for future removal of the pressurizer; (4) removing the Unit 3 main steam system piping and steam generator insulation for disposal; and (5) constructing temporary ventilation systems to replace the containment purge systems in both containments. Other activities in progress included removal of trash and debris from the containments for disposal, final draining and decontamination of the Unit 2 SFP, and removal of the remaining spent fuel racks from the Unit 3 SFP room. Future work will include construction of the material handling facility to support future waste loading operations and cleanup of the oily waste sump.
1 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 license and regulatory 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 completion of the decommissioning and decontamination work. At the time of the inspection, the licensee and its decommissioning general contractor SDS were conducting major 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 different classes of wastes for disposal. In Unit 2, the contractor was actively cutting the lower core shroud core plate and lower core support columns. These cuts were being made, in part, to separate the Class B waste material from the greater-than-Class C (GTCC) waste material. The work was being conducted using cutting plans provided in work packages SDS-2-M-CO-372 and 392. In Unit 3, the contractor was cutting the lower support cylinder, part of the lower support assembly. The work was being conducted in accordance with the cutting plans provided in work packages SDS-3-M-CO-420 and SDS-3-M-CO-432.
In discussions with licensee and contractor staff, the reactor vessel internals segmentation project was behind schedule since the components located in the lower levels were more radioactive than originally anticipated. For this reason, the lower components must be cut into smaller segments for proper separation of wastes, packaging, and disposal.
The GTCC wastes continued to be loaded into storage liners for eventual transfer and interim storage at the onsite ISFSI. The GTCC wastes will be loaded into 10 liners, five per unit. The remainder of the vessel internals will be packaged for offsite disposal as either Class A or Class B/C radioactive wastes. The inspectors concluded that the contractors were conducting the work in accordance with approved site procedures.
The inspectors toured the Unit 2 and Unit 3 containments and observed general work in progress. The work included preparing several reactor coolant pump motors for removal, cutting of metal and concrete interferences for future removal of large components, and removal of reactor coolant system piping and steam generator insulation for disposal.
Housekeeping was adequate in both containments, and the radiological controls were consistent with regulatory requirements in the two restricted areas. The inspectors observed the movement of containerized wastes from both containments for disposal.
The movement activities were closely monitored by the contractors health physics staff.
During tours of the Unit 3 containment, standing water was observed on the basement floor. Site staff indicated that the water was primarily rainwater that will be removed upon receipt and installation of containment sump support equipment. The licensee issued an action request (AR 0923-32970) to investigate the reasons for the standing water and to recommend corrective actions to prevent recurrence of the incident.
Outside of the containments, decommissioning work in progress included removal of the remaining spent fuel racks from the Unit 3 SFP room. The inspectors observed the
packaging of two racks for offsite disposal. The movement of the racks was facilitated by a 24-wheel vehicle. The work was well managed by contractor staff including implementation of radiation protection controls. The inspectors observed the final draining and decontamination of the Unit 2 SFP transfer canal.
The inspectors also observed the demolition of the former multipurpose handling facility located at the southern end of the site. The demolition debris was being moved to the site restricted area for packaging, transportation, and offsite disposal as Class A wastes.
Other work in progress included construction of the material handling facility, a structure that will be used to provide a controlled environment for future loading of loose radioactive wastes into shipping containers. The inspectors noted that the decommissioning work was being conducted with an emphasis on personnel safety.
The inspectors conducted independent radiological assessments using a hand-held survey meter, a Radeye G gamma survey meter (serial number 13427, calibration due date 3/31/24). Posted survey results were consistent with existing postings.
1.3 Conclusion The licensee and its decommissioning contractor were conducting decommissioning in accordance with the instructions provided in site procedures and commitments provided in the PSDAR.
2 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (Inspection Procedure 84750)
2.1 Inspection Scope The objectives of this portion of the inspection were to ensure that: (1) the radwaste treatment systems were being managed in accordance with site procedures; (2) radioactive effluent sampling and analysis requirements were being satisfied so that discharges of radioactive materials were adequately quantified and evaluated; (3) the radiological environmental monitoring programs were effectively implemented; and (4)
the voluntary groundwater protection initiative was being implemented as specified in the PSDAR.
2.2 Observations and Findings a. Environmental Monitoring The inspectors conducted a review of the environmental monitoring program which included field observations of equipment and procedural implementation and records associated with the program. During the inspection, the inspectors reviewed procedure SDS-CH2-PCD-1014, Annual and Semiannual REMP Sampling, and observed the collection of a soil sample. The inspectors also reviewed and observed the operation of two air monitoring stations. The inspectors did not identify any deficiencies in the implementation of the procedure, and the air samplers were in proper working order at the time of the inspection.
The inspectors also reviewed the licensees, Annual Radioactive Effluent Release Report - 2022 San Onofre Nuclear Generating Station (SONGS), Units 1, 2 and 3
Docket Nos. 50-206, 50-361 and 50-362, dated April 28, 2023 (ML23123A093). The inspectors did not identify any deficiencies or concerns.
b. Groundwater Protection Initiative The inspectors reviewed the licensees, Ground Water Protection Initiative Voluntary Communication Protocol, SO123-XV-3.5 ISS2, revision 11, during the inspection, specifically focusing on on-site ground water management. The inspectors did not identify any significant deficiencies in the licensees implementation of this voluntary initiative.
c. Liquid Effluent Storage and Treatment System The inspectors conducted a review and walkdown of the liquid radwaste processing system. The current system consisted of a portable liquid radwaste processing skid, storage locations, discharge pathways, radiation monitors, and associated instrumentation and controls. At the time of the inspection, the sources of liquid radioactive effluents included the liquids stored in the radwaste system tanks, spent fuel pool, and reactor cavity.
During a walkdown of the liquid radwaste processing system, the inspectors reviewed wastewater container integrity, liquid flow pathways, radiation monitoring system and effluent discharge points using drawing SDS-EN1-DWG-49200 (P&I Diagram SONGS Mobile Liquid Radwaste Processing System). The system was not in operation at the time of the inspection. The inspectors noted that the system was installed as per design, and no abnormal issues were identified.
2.3 Conclusion The NRC reviewed the licensees: (1) environmental monitoring equipment and observed implementation of sampling procedures; (2) Groundwater Protection Initiative program; and (3) liquid effluent storage and treatment system. The inspectors did not identify any significant deficiencies or violations of NRC requirements.
3 Exit Meeting Summary On September 14, 2023, the inspectors presented the final inspection results to the Chief Nuclear Officer/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.
SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee and Contractor Personnel C. Aung, SDS, Chemistry D. Bauder, SCE, Chief Nuclear Officer and Vice President Decommissioning J. Carey, SCE, Multi-Discipline Cause Manager R. Corbett, SDS, Radiation Protection Manager G. Huff, SDS, Chemistry J. Janke, SCE, ISFSI Manager R. Kalman, SDS, Executive Sponsor J. Madigan, SCE, Nuclear Oversight and Safety Culture Manager S. Mannon, SDS, Regulatory Affairs Manager M. Morgan, SCE, Regulatory Affairs H. Neely, SCE, Environmental Services J. Peattie, SCE, General Manager R. Pontes, SCE, General Manager L. Rafner, SCE, Regulatory Affairs S. Sewell, SCE, Radiation Protection and Waste Manager J. Stephenson, SCE, Manager V. Bilovsky, SCE, Decommissioning Project Director INSPECTION PROCEDURES USED IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring LIST OF ITEMS OPENED, CLOSED, and DISCUSSED Opened None Discussed None Closed None Attachment
LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations GTCC greater-than-Class C ISFSI Independent Spent Fuel Storage Installation NRC Nuclear Regulatory Commission PSDAR Post Shutdown Decommissioning Activities Report REMP Radiological Environmental Monitoring Program SDS SONGS Decommissioning Solutions SFP spent fuel pool SONGS San Onofre Nuclear Generating Station 2