IR 05000361/2024001
| ML24024A162 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/13/2024 |
| From: | Greg Warnick NRC/RGN-IV/DRSS/DIOR |
| To: | Bailly F Southern California Edison Co |
| Dennes C | |
| References | |
| IR 2024001 | |
| Download: ML24024A162 (14) | |
Text
February 13, 2024
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2024-001 AND 050-00362/2024-001
Dear Frederic Bailly:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on January 8-11, 2024, 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 preliminary exit meeting on January 11, 2024. The final exit meeting was provided to you and your staff on February 8, 2024. 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, independent measurement of radiation levels, and interviews with personnel. Specifically, the inspectors reviewed your implementation of decommissioning activities, problem identification and resolution, and remedial and final surveys. Within the scope of the inspection, no violations were identified, and no response to this letter is required.
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. The violation involves your failure to comply with technical specification requirements to prevent unauthorized access to a locked high radiation area. Since you placed the deficiency into your corrective action program, the safety significance of the issue was determined to be low, and because the violation was non-repetitive and not willful, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRCs Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: (1) the Regional Administrator, Region IV; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. 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, 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 050-00361/2024-001; 050-00362/2024-001 w/Attachment: Supplemental Inspection Information Distribution via LISTSERV Signed by Warnick, Gregory on 02/13/24
ML24024A162 SUNSI Review By:CRD2 ADAMS:
Yes No Sensitive Non-Sensitive Non-Publicly Available Publicly Available Keyword NRC-002 OFFICE HP:DIOR/DRSS SHP:DIOR/DRSS C:DIOR/DRSS NAME CDennes REvans GGWarnick SIGNATURE
/RA/
/RA/
/RA/
DATE 01/25/24 01/25/24 02/13/24
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.
050-00361; 050-00362 License Nos.
050-00361/2024-001; 050-00362/2024-001 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 8-11, 2024 Inspectors:
Robert J. Evans, PE, CHP, PhD, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Christian R. Dennes, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Accompanied By:
Tammy E. Bloomer, Director 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 05000361/2024-001; 05000362/2024-001 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at San Onofre Nuclear Generating Station, 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, with one exception as described below.
Decommissioning Performance and Status Review
The licensee and its decommissioning general contractor were conducting activities in accordance with the instructions provided in site procedures and commitments provided in the Post-Shutdown Decommissioning Activities Report. Radiological controls and related postings were being maintained. (Section 1.2)
Problem Identification and Resolution at Permanently Shutdown Reactors
The licensee and its decommissioning general contractor established and implemented comprehensive corrective action programs to identify, resolve, and prevent conditions adverse to quality. The licensee and its contractor implemented quality assurance audit programs in accordance with regulatory and procedural requirements. The licensee and its contractor established and implemented employee concerns programs in accordance with site procedures. A Severity Level IV non-cited violation was identified involving the unauthorized entry of a worker into a locked high radiation area contrary to technical specifications requirements. (Section 2.2)
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors
The licensees contractor implemented an unconditional release survey program for the control building in accordance with commitments provided in the Post-Shutdown Decommissioning Activities Report and site procedures. (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 that it had permanently ceased power operations at San Onofre Nuclear Generating Station (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 outlined the licensees planned decommissioning activities. The current version of the PSDAR is dated May 7, 2020 (ML20136A339). As discussed in the PSDAR, the licensee chose 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 Energy Solutions as the decommissioning general contractor. The joint venture between the two companies was named SONGS Decommissioning Solutions (SDS). The SDS organization manages most of the decommissioning activities as described in the PSDAR.
During the inspection week, decommissioning activities in progress included continued removal of components from within the two containments structures for offsite disposal. In Unit 2, the final portions of the reactor vessel internals and the steam generators were being cut for removal and disposal. In Unit 3, the contractor completed the cutting of the reactor vessel internals and was preparing the steam generators for future cutting and removal. The contractor was also conducting unconditional release surveys in the control building to support future demolition of the building. Near term work projects include removal of the pressurizers from containment structures and removal of the remainder of the greater-than-Class-C material from the two reactor cavities. The greater-than-Class-C material will be placed in liners and stored in canisters on an interim basis at the onsite Independent Spent Fuel Storage Installation.
Decommissioning Performance and Status Review at Permanently Shutdown Reactors (IP 71801)
1.1 Inspection Scope 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. To maintain awareness of work activities to assess licensee control and conduct of decommissioning.
1.2 Observations and FindingsSection II.A of the PSDAR provides a description of the decommissioning periods. The site is currently in Period 4. This period started with the completion of fuel transfer operations in August 2020 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 decommissioning schedule with management staff and conducted site tours to observe work in progress.
Inside the Unit 2 containment, the licensees contractor was completing the final cuts of the reactor vessel internals. The lower support assembly, located at the bottom of the core support barrel, was being cut in accordance with procedure SDS-2-M-CO-393, U2-Lower Support Assembly Cut Plan, revision 0. The inspectors discussed the implementation of the work plan with the craft who were conducting the work.
In addition, the contractor was cutting and removing the two steam generators (88 and 89) from the Unit 2 containment. The inspectors observed the work in progress. At the time of the inspection, the dryer assemblies had been removed from both steam generators. The moisture separator assembly had been removed from steam generator 88. During the inspection, the heat transfer tube bundle in steam generator 88 was being segmented using the general instructions provided in procedure SDS-2-M-CO-1129, Decommissioning Work Package, revision 0. The Inconel tubes were being cut with an oxylance thermal cutting device. The segmented tubes were being placed in a container for future disposal. The contractor was also removing the outer shell of Section 4 of steam generator 89, in preparation for removal of the moisture separators from that steam generator.
In the Unit 3 containment, the contractor was preparing the two steam generators for future removal. The contractor was also in the early stages of preparing for segmentation of the Unit 3 reactor pressure vessel shell. The inspectors observed the mockup that was being used to train workers for future cutting of the reactor vessel shell.
At the time of the inspection, six of eight reactor coolant pump motors have been removed from the two containments and shipped offsite for disposal. The remaining two motors will be removed later. The contractor continued to prepare for future removal of the pressurizers from both units. As discussed in Section 3.2 below, the contractor was also conducting unconditional release surveys in the control building in preparation for future demolition of the building including the control room.
The inspectors conducted independent radiological assessments during site tours using a hand-held survey meter, a Radeye G gamma survey meter (serial number 13427, calibration due date 3/31/24). The inspectors confirmed that posted signs and survey results were consistent with regulatory requirements.
1.3 Conclusion The licensee and its decommissioning general contractor were conducting activities in accordance with the instructions provided in site procedures and commitments provided in the PSDAR. Radiological controls and related postings were being maintained.
2 Problem Identification and Resolution at Permanently Shutdown Reactors (IP 40801)
2.1 Inspection Scope To evaluate the effectiveness of licensee controls in identifying, resolving, and correcting issues in accordance with the quality assurance (QA) program and 10 CFR Part 50, Appendix B requirements. To determine whether audits and assessments were conducted in accordance with the QA program and regulatory requirements. To confirm that the licensee has established, implemented, and performed management reviews of the safety-conscious work environment.
2.2 Observations and Findings a.
Corrective Action Programs Corrective action programs are required by 10 CFR Part 50, Appendix B, Criterion VXI and Sections 16 of the licensees Decommissioning Quality Assurance Program (DQAP), revision 9, and SDSs Quality Assurance Program (QAP), Procedure SDS-QA1-PGM-0001, revision 5. The two QA plans were assessed for effectiveness at reasonably preventing problems and promptly detecting and correcting issues of concerns, conditions adverse to quality, and non-conformances. The review include attendance at a licensees corrective action review meeting.
The inspectors reviewed the details of the licensees corrective action program in procedure ADM-5, Corrective Action Program, revision 5. Details of the contractors program were provided in procedure SDS-RA1-PGM-0005, Corrective Action Program, revision 8. The inspectors attended Action Request meetings, which were conducted to review problems that have been identified and review root causes and corrective actions with a focus on preventing reoccurrence. Additionally, the inspectors interviewed both corrective action program (CAP) managers about program trends, challenges faced, management engagement, and future for improvement and development items or plans.
The inspectors reviewed selected corrective action reports issued since the last inspection of this program area. The reviewed topics included a fuel handling building crane coming into contact with a scaffold and the unintentional creation of a very small fire during steam generator cutting operations. The inspectors noted that the contractor took thorough and comprehensive corrective actions in response to each incident and none of the events impacted nuclear safety.
The inspectors conducted a detailed review of SDS condition report 001816 involving a worker who inappropriately entered a locked high radiation area (LHRA) in Unit 3 containment. On December 11, 2023, a worker entered a LHRA on the wrong radiation work permit (RWP) task number. The worker was authorized to enter high radiation areas, but not LHRAs. Although a radiation protection technician accompanied the worker at all times, the worker was not authorized by the RWP to enter the LHRA. More than one administrative program barrier failed to prevent the individuals entry into the LHRA on the wrong RWP task.
The Unit 3 license NPF-15, condition 2.C(2) states that the licensees staff shall operate the facility in accordance with the technical specifications. Technical specification 5.8.2
states, in part, that areas accessible to personnel and that have radiation levels greater than 1.0 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source shall be provided with locked doors to prevent unauthorized entry. Technical Specification 5.8.2 further states that doors shall remain locked except during periods of access by personnel under an approved RWP.
Contrary to the above, on December 11, 2023, the licensee failed to follow technical specification 5.8.2 when an unauthorized individual entered an area that had radiation levels greater than 1.0 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source. Specifically, a worker was provided access to a LHRA when not on an approved RWP as they were on an RWP task that only authorized entry into high radiation areas.
Using Section 6.7 of the NRC Enforcement Policy for guidance, the NRC determined the significance of the violation is Severity Level IV since there was the potential to lead to a more significant safety concern because of an ineffective radiation program barrier.
Specifically, an improper entry was made into an LHRA areas. In response to the event, SDS issued condition report 001816 to document the corrective actions necessary to prevent the reoccurrence of the incident. Thus, this non-repetitive, licensee-identified, and corrected violation is being treated as a Severity Level IV non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 050-00362-24-01-01).
b.
Quality Assurance Audit Programs Quality assurance audits are required by 10 CFR Part 50, Appendix B, Criterion XVIII.
The instructions for the audits were provided in Sections 18 of the licensees DQAP and the SDS QAP. Details of the programs are provided in the licensees procedure NOD-2, Audit and Assessment Program, revision 6, and the contractors procedure SDS-QA1-PCD-0011, Audit and Surveillance, revision 8. The inspectors reviewed the audits and assessments to verify that the audits are being performed consistent with the schedule outlined in the QA program plan.
The inspectors interviewed the SDS and SCE Quality Assurance managers as well as reviewed documents that demonstrate compliance with 10 CFR Part 50, Appendix B, Criterion XVIII. Both the licensee and its decommissioning contractor maintain a robust and regularly scheduled audit and surveillance program. The licensee regularly questions and investigates the findings identified by the contractor. Both programs have regular third-party audits of their programs.
c.
Safety Conscious Work Environment The NRCs Regulatory Issue Summary 2005-18 provides the guidance for establishing and maintaining a safety-conscious work environment. In support of positive nuclear safety cultures, both the licensee and SDS had established employee concerns programs. The licensees program was described in procedure ADM-2, Decommissioning Employee Concerns Program, revision 2, and SDSs program was described in procedure SDS-RA1-PGM-0004, Employee Concerns, revision 2.
The inspectors conducted separate interviews of the Employee Concern Program managers for both the licensee and the decommissioning contractor. Both program managers were engaged with the work force and had regular as well as meaningful
interaction with management. Additionally, the inspectors had discussions with random employees to further assess the culture and environment.
2.3 Conclusion The licensee and its decommissioning general contractor established and implemented comprehensive corrective action programs to identify, resolve, and prevent conditions adverse to quality. The licensee and its contractor implemented QA audit programs in accordance with regulatory and procedural requirements. The licensee and its contractor established and implemented employee concerns programs in accordance with site procedures. An NCV was identified involving the unauthorized entry of a worker into a LHRA contrary to technical specifications requirements.
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors (IP 83801)
3.1 Inspection Scope To verify that permanently shut down power reactor sites have been decontaminated to acceptable residual radioactivity levels and to verify that the licensees implementing procedures, radiological measurements, decommissioning surveys, and documentation of decommissioning surveys comply with approved procedures.
3.2 Observations and FindingsSection II.B.3 of the PSDAR states that the decontamination and/or dismantlement of contaminated systems, structures, and components may be accomplished by decontamination in place, decontamination and dismantlement, or dismantlement and disposal. The methods chosen will be those deemed most appropriate for the circumstances. Material below the applicable radiological limits may be released for unrestricted disposition including recycling.
During the inspection period, the licensees contractor was conducting unconditional release surveys within the control building with the goal to free release portions of the building in place to allow for recycling of some of the components located within the building. The inspectors conducted a review of the contractors survey efforts, observed surveys in progress, and interviewed pertinent staff to ensure compliance with approved site procedures.
The instructions for the control building survey were provided in procedure SDS-LT1-PCD-1003, Unconditional Release of Structures, Systems, and Miscellaneous Material and Equipment, revision 5. As noted in the procedure, the decision to release an area, such as the control building, is based on information and survey results provided in the historical site assessment, site characterization report, sentinel surveys (surveys conducted to ensure an area is ready for a final status survey), and the unconditional release surveys.
After a structure has been unconditionally release surveyed, and the results meet the release criteria, the structure is demolished, and the various materials are separated for waste disposal, recycling, or asset recovery. As final checks, the loaded shipping
container is hand-surveyed to ensure it meets the release criteria, and outbound truck shipments are surveyed using a portal monitor just prior to departure from the site.
The inspectors reviewed selected historical site assessments, site characterization report, sentinel surveys, survey plans, and quality control surveys for future unconditional release of the control building. The inspectors also observed implementation of radiological surveys in progress. Finally, the inspectors reviewed the contactors QA oversight of the final status survey program.
The inspectors reviewed the licensees historical site assessment dated February 2015 that discussed the historical use of the control building and the equipment located in and around the building. The report noted that several rooms at the 70-foot elevation were previously used to support radiological activities; therefore, these areas may contain residual radioactive material. The report also included a discussion of the non-radiological contaminants such as oil and grease. The site characterization report dated January 2014 included the characterization radiological survey results of each area within the control building. The survey results confirmed that portions of the control building at the 70-foot elevation contained measurable quantities of radioactive material.
In addition, the contractor conducted sentinel surveys in the control building to supplement the characterization survey information. The inspectors reviewed selected sentinel survey results.
Based in part on these survey results, the contractor developed unconditional release survey plans for the areas and components of control building that could be free released in place. These surveys were in progress during the inspection. The inspectors confirmed that the survey crew was conducting surveys in accordance with the instructions provided in site procedures, and the survey crew were using calibrated equipment for the type of survey being conducted.
As required by procedure SDS-LT1-PCD-1003, the contractor also performed periodic surveys or surveillances of areas that had been previously surveyed, to monitor for indications of cross-contamination and to verify postings and access control measures.
The inspectors reviewed a representative surveillance survey that was recently completed. The results of the survey indicate that cross-contamination had not occurred at the time of the survey.
Finally, the inspectors reviewed the status of the QA program and CAP oversight of the unconditional release survey program. The contractors QA auditors conducted a surveillance of the program in February 2023. The QA auditor identified several findings, deficiencies, recommendations, and observations. These findings were entered into the contractors CAP for resolution. The inspectors also reviewed the index of CAP issues involving the final status and unconditional release survey program. None of the identified problems appeared to be significant or detrimental to the quality of the survey program.
3.3 Conclusion The licensees contractor implemented an unconditional release survey program for the control building in accordance with commitments provided in the PSDAR and in accordance with site procedures.
4 Exit Meeting Summary The inspectors presented the preliminary inspection results to the Chief Nuclear Officer/Vice President Decommissioning and other members of the licensees staff on January 11, 2024. The final inspection results were presented to the licensee on February 8, 2024. 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 N. Alchaar, Business Services Senior Project Manager F. Bailly, SCE, Vice President, and Chief Nuclear Officer V. Bilovsky, SCE, Decommissioning Project Director C. Boschetti, SDS, Quality Manager D. Brice, SONGS Decommissioning Council M. Camargo, SCE, Strategic Planning and Stakeholder Engagement Manager J. Carey, SCE, Corrective Action Program Manager C. Cates, SCE, Employee Concerns Program R. Corbett, SDS, Radiation Protection Manager R. Kalman, SDS, Executive Sponsor J. Madigan, SCE, Regulatory Affairs, Nuclear Oversight and Safety Culture Manager S. Mannon, SDS, Programs Project Director/Regulatory Manager M. Morgan, SCE, Nuclear Licensing Manager L. Mosher, SCE, Communications Manager J. Peattie, SCE, General Manager S. Sewell, SCE, Radiation Protection Manager R. Sholler, SDS, Final Status Survey Project Manager INSPECTION PROCEDURES USED IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 40801 Problem Identification and Resolution at Permanently Shutdown Reactors IP 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed 050-00362-24-01-01 NCV Unauthorized entry into LHRA Discussed None
A-2 LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CAP corrective action program CFR Code of Federal Regulations DQAP Decommissioning Quality Assurance Program IP Inspection Procedure LHRA locked high radiation area NCV non-cited violation NRC Nuclear Regulatory Commission PSDAR Post Shutdown Decommissioning Activities Report QA quality assurance QAP Quality Assurance Program RWP radiation work permit SCE Southern California Edison Company SDS SONGS Decommissioning Solutions SONGS San Onofre Nuclear Generating Station