IR 05000361/2025001
| ML25045A210 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/26/2025 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Bailly F Southern California Edison Co |
| Evans R | |
| References | |
| IR 2025001 | |
| Preceding documents: |
|
| Download: ML25045A210 (1) | |
Text
February 26, 2025
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2025-001; 050-00362/2025-001 AND NOTICE OF VIOLATION
Dear Frederic Bailly:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted onsite from January 27-30, 2025, for San Onofre Nuclear Generating Station, Units 2 and 3.
The inspectors discussed the preliminary inspection results with you and members of your staff at the end of the onsite inspection on January 30, 2025. The final inspection results were presented to you via Microsoft Teams meeting on February 11, 2025. The inspection results are documented in the enclosures 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 decommissioning performance; remedial and final surveys; safety reviews, design changes, and modifications; and solid radioactive waste management and transportation of radioactive materials.
The enclosed report discusses a Severity Level IV violation related to the licensees failure to implement the fire protection program as required by 10 CFR 50.48(f)(1). This violation was evaluated in accordance with the NRC Enforcement Policy, which can be found on the NRC website at http://www.nrc.gov/aboutnrc/regulatory/enforcement/enforce-pol.html. The violation is cited in Enclosure 1, Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject inspection report (Enclosure 2). The NRC determined that this violation did not meet the criteria to be treated as a non-cited violation (NCV) because the issue was not entered into a credited corrective action program and the corrective actions taken were not adequate, consistent with Section 2.3.2 of the NRC Enforcement Policy. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosures, and your response 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 Eric McManus at 817-200-1127 or the undersigned at 817-200-1249.
Sincerely, Jeffrey E. Josey, Chief Decommissioning, ISFSI, Operating Reactor Branch Division of Radiological Safety and Security Docket Nos. 50-361; 50-362 License Nos. NPF-10; NPF-15
Enclosures:
1. Notice of Violation 2. Inspection Report 050-00361/2025-001; 050-00362/2025-001 w/Attachment: Supplemental Inspection Information Distribution via ListServ Signed by Josey, Jeffrey on 02/26/25 SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2025-001; 050-00362/2025-001 AND NOTICE OF VIOLATION - DATED FEBRUARY 26, 2025 DISTRIBUTION:
JMonninger, ORA JLara, ORA JGroom, DRSS NOKeefe, DRSS RAlexander, ORA DCylkowski, ORA VDricks, ORA TSmith, ORA AAlen-Arias, OEDO/ETA SAnderson, NMSS/DUWP/RDB ASnyder, NMSS/DUWP/RDB LWilkins, OCA AMoreno, RIV/OCA R4-DRSS-DIOR-DECOM
DOCUMENT NAME: SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2025-001; 050-00362/2025-001 AND NOTICE OF VIOLATION ADAMS A
REGION IV==
Docket Nos.
050-00361; 050-00362 License Nos.
050-00361/2025-001; 050-00362/2025-001 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:
Onsite January 27-30, 2025 Exit Date:
February 11, 2025 Inspectors:
Robert J. Evans, PE, CHP, PhD, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Eric S. McManus, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Accompanied by:
Tiffany N. Rushing, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Approved By:
Jeffrey E. Josey, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Attachment:
Supplemental Inspection Information
EXECUTIVE SUMMARY San Onofre Nuclear Generating Station NRC Inspection Report 050-00361/2025-001; 050-00362/2025-001 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. In summary, the licensee and its decommissioning general 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 Reviews at Permanently Shutdown Reactors
The licensee was effectively implementing decommissioning activities at Units 2 and 3 in accordance with approved procedures and commitments provided in the PSDAR. The licensee maintained good radiological control over these work activities. (Section 1.2)
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors
The licensee implemented final status survey isolation and control measures in accordance with approved procedures. The licensee continued to identify, document, and resolve problems in the final status survey program area. (Section 2.2)
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
The licensee developed and implemented a written program for safety reviews, design changes, and modifications. The program was being implemented by qualified individuals.
Based on a limited NRC review of recently issued safety reviews, the licensee was noted to be effectively implementing the program. (Section 3.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials
The inspectors reviewed selected radioactive waste management and transportation activities and identified one violation of regulatory requirements. The violation involved the licensees failure to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials. (Section 4.2)
Report Details Summary of Plant Status Southern California Edison Company (SCE), the licensee, formally notified the NRC in June 2013 that it had permanently ceased power operations at San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML131640201). The NRC subsequently issued the permanently defueled technical specifications in July 2015 (ML15139A390), along with revised facility operating licenses to reflect the permanent cessation of operations at Units 2 and 3.
As required by Title 10 to 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 revised 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, the licensee was preparing the rigging equipment for the Unit 3 reactor vessel lift and subsequent segmentation of the vessel shell. In Unit 2, the licensee removed the final reactor coolant pump and prepared it for shipment to a disposal site. The material handling facility was operational for open air demolition of the site radioactive structures.
Decommissioning Performance and Status Review at Permanently Shutdown Reactors (Inspection Procedure [IP] 71801)
1.1 Inspection Scope The inspectors observed site activities, reviewed documents, and interviewed site personnel in order to: (1) evaluate the status of decommissioning and verify whether the licensee was conducting decommissioning and maintenance activities in accordance with regulatory and license requirements; (2) evaluate the licensee awareness of work activities to assess their control and conduct of decommissioning; and (3) evaluate the licensees decommissioning staffing, personnel qualifications, and training requirements, including that of the contracted workforce, to ensure that license requirements were met, as applicable to the current decommissioning status.
1.2 Observations and Findings a.
Status of Decommissioning At the time of the onsite inspection, the licensee and its decommissioning general contractor SDS were conducting major decommissioning activities in accordance with the commitments provided in Section II.B.1 of the PSDAR. The inspectors discussed the
current decommissioning schedule with management staff, observed daily planning meetings, and observed open air demolition work in progress. The status of decommissioning was noted to be commensurate with the challenges encountered.
During the onsite inspection, the Units 2 and 3 radwaste buildings were being demolished. The building demolition work was approximately 90-percent complete.
The inspectors attended meetings that included discussion of decommissioning activities as well as the current plant status for each day. The topics discussed included an As Low As Is Reasonably Achievable (ALARA) briefing, safety briefing, current work projects, and near-term work projects. The meeting provided participants with current information of the work in progress including radiological and industrial safety updates as needed.
The inspectors performed tours of the Unit 2 and Unit 3 containment buildings, facilities adjacent to the containment buildings, and the former location of the multipurpose handling facility in the south yard area. 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. The inspectors identified good housekeeping practices and appropriate radiological postings and labeling. The inspectors did not identify any radiological areas that were not adequately identified and posted by the licensee.
The inspectors conducted site tours, in part, to observe open air demolition activities.
The work was being conducted in accordance with the instructions provided in SDS-RP1-TSD-24-01, Open-Air Demolition Plan for San Onofre, revision 2, The licensee was demolishing the buildings, sorting the debris, transferring the debris to the adjacent material handling facility, and loading the debris into railcars for offsite disposal.
The inspectors reviewed the radiological status of the open-air demolition project. The radiological work control requirements were provided in Radiation Work Permit 25-0-77, revision 0. The permit included worker requirements for dosimetry, protective clothing, and respiratory protection. The inspectors reviewed the actual and budgeted dose estimates for the demolition workers for 2025. At the time of the inspection, the combined assigned doses to demolition workers were about 38 millirem with an annual budgeted dose of 495 millirem. In summary, the licensee continued to monitor demolition workers for exposure to radiation and radioactive material, and actual doses were consistent with the estimated doses for the project.
The open-air demolition plan also provides instructions for daily environmental air sampling, workplace air sampling, contamination surveys, and dose rate surveys. The inspectors reviewed the results for the January 28, 2025, daily sampling, in part, to determine if contamination was spreading outside of the demolition work area. The daily results did not identify surface contamination outside of the work area, and relatively low exposure rate readings were identified inside the work area. The licensee continued to conduct daily sampling as required by the open-air demolition plan, and the daily results indicated no release of contamination outside of the work area during the inspection.
b.
Observation of Decommissioning Work Activities in Units 2 and 3 Containments The inspectors toured the Units 2 and 3 containments to observe work in progress and to independently assess radiological conditions. In Unit 2, the licensee continued to prepare for future reactor segmentation activities including the cutting of the vessel nozzles. The licensee completed the cutting and removal of the two steam generators.
The licensee removed the final reactor coolant pump from the containment building during the inspection. The other three reactor coolant pumps were still onsite, awaiting packaging and offsite shipment for disposal.
In Unit 3, the major work activities included continued preparation for future cutting of the reactor vessel shell. The licensee continued to cut and remove the remainder of the steam generators from the containment building. All four reactor coolant pumps had been removed from containment and shipped offsite for disposal.
The inspectors observed strong radiation protection support in both containments.
Housekeeping was adequate based on the work in progress. A minor radioactive labeling issue was identified and reported to the radiation protection staff for resolution.
The inspectors conducted independent radiological surveys during site tours using a Thermo Scientific Radeye G survey meter (serial number 13420, calibration due date of 7/23/2025, calibrated to cesium-137). Overall, the measured exposure rates were consistent with existing signs, boundaries, and postings.
The licensee and its decommissioning contractor were conducting decommissioning activities in accordance with the instructions provided in site procedures and commitments provided in the PSDAR.
c.
Decommissioning Staffing and Training As described in Section 3.2 below, the inspectors conducted a review of the training and qualification program for personnel conducting 10 CFR 50.59 safety reviews, design changes, and modifications. In summary, the training was conducted in accordance with procedure requirements, and all reviewers were found to be trained and qualified to conduct their assigned reviews.
1.3 Conclusions The licensee was effectively implementing decommissioning activities at Units 2 and 3 in accordance with approved procedures and commitments provided in the PSDAR. The licensee maintained good radiological control over these work activities.
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors (IP 83801)
2.1 Inspection Scope The inspectors observed site activities, reviewed documents, and interviewed site personnel to verify that permanently shut down power reactor sites have been decontaminated to acceptable residual radioactivity levels and to verify that the licensees procedures, radiological measurements, decommissioning surveys, and
documentation of decommissioning surveys were implemented in accordance with NRC guidance.
2.2 Observations and Findings a.
Remediation Activities and Final Status SurveysSection II of the PSDAR states that appropriate radiological and environmental programs will be maintained throughout the decommissioning process to ensure radiological safety of the workforce and the public, and environmental compliance is maintained. The inspectors reviewed selected areas of the licensees final status survey and radiological assessment programs to ensure that surveys were being conducted in accordance with procedural requirements. Specifically, the inspectors reviewed the licensees implementation of its final status survey isolation and control measures.
The isolation and control measures are described in procedure SDS-LT1-PCD-1008, Final Status Survey Isolation and Control Measures, revision 2, isolation and control measures are used to limit the potential for cross-contamination from other decommissioning activities and to maintain the final configuration of the applicable survey units. These measures are implemented for survey units that are ready for final status surveys and survey units that have been final status surveyed. The measures include access control to the survey units, installation of postings and boundaries, and post-survey surveillances.
At the time of the inspection, the areas that were under isolation and control included the Unit 3 intake gate No. 1, former makeup demineralizer area, former multipurpose handling facility area, electrical tunnels, and tendon galleries. Other previously surveyed areas included the underground intake and discharge tunnels that were previously backfilled with a flowable fill material and are no longer accessible.
The inspectors conducted site tours, in part, to observe the accessible areas being managed with isolation and control measures. All areas were properly posted with signs and boundaries. The inspectors also reviewed the licensees program for managing the post-turnover surveillances. The licensee had established and implemented a program consistent with procedure requirements. All surveillances were found to be up-to-date.
No evidence of cross-contamination had been identified by the licensee in any final status survey unit at the time of the inspection.
b.
Verification and Confirmatory Surveys The inspectors did not conduct independent confirmatory or verification surveys during this inspection.
c.
Problem Identification and Resolution The inspectors reviewed recent corrective action program entries involving final status surveys. The decommissioning contractor was writing Condition Reports (CR) to address problems as they were identified. Recent issues that were documented in CRs included a missed meter response background check and clarification of training requirements. For all CRs, the licensee developed and implemented corrective actions to prevent reoccurrence of the identified problems.
2.3 Conclusions The licensee implemented final status survey isolation and control measures in accordance with approved procedures. The licensee continued to identify, document, and resolve problems in the final status survey program area.
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (IP 37801)
3.1 Inspection Scope The inspectors reviewed documents and interviewed site personnel to verify that the licensees safety review process was being implemented in accordance with the requirements of 10 CFR 50.59, Changes, Tests, and Experiments. The inspectors reviewed the licensees implementation of its safety review programs, selected design changes and completed safety reviews, training and qualification of reviewers, and SDS CRs issued in this program area.
3.2 Observations and Findings a.
Safety Reviews, Design Changes, and Modifications The licensees programs are described in procedures ENG-3, 10 CFR 50.59, 72.48, and 50.82 Program, revision 1, and SDS-RA1-PGM-0002, 10 CFR 50.59 and 72.48 Program, revision 3. The inspectors reviewed recently issued safety reviews, design changes, and modifications. These reviews included:
Elimination of the exclusion area boundary and clarification of site boundary due to the absence of off-site design-basis accident consequences
Installation of protective enclosures over the lower beach discharge flap valves to prevent rocks and cobble from obstructing valve operation during rainstorms
Abandonment of the onsite sewage treatment plant and oily waste holding sumps, and to remove the components from the defueled safety analysis report
Modify, mobilize, and relocate the liquid radioactive waste system from plant equipment to a mobile platform to allow for demolition of the radwaste building
Verification of the tornado missile protection requirements for tank T-351 to allow the tank to be used for temporary storage of radioactive water The inspectors noted that the reviews were conducted and documented by trained and qualified individuals. No findings of significance were identified during the NRC review of these safety reviews.
b.
Training and Qualification Program Review Procedure ENG-3, 10 CFR 50.59, 72.48, and 50.82 Program, revision 1, Section 5.4 provided the qualification requirements for SCE staff, while procedure SDS-RA1-PGM-0002, 10 CFR 50.59 and 72.48 Program, revision 3, Section 3.2.2, Attachment 5.1 and Attachment 5.2 provided the training requirements for SDS staff. The inspectors reviewed both training programs and discussed the programs with representatives from
each organization. Both programs had a sufficient number of qualified individuals to implement the respective programs, and the qualifications were consistent with procedure requirements.
c.
Problem Identification and Resolution There were no recent SCE Action Request (AR) or contractor CRs of significance issued in this program area.
3.3 Conclusions The licensee developed and implemented a written program for safety reviews, design changes, and modifications. The program was being implemented by qualified individuals. Based on a limited NRC review of recently issued safety reviews, the licensee was noted to be effectively implementing the program.
Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)
4.1 Inspection Scope The inspectors observed site activities, reviewed documents, and interviewed site personnel to verify the effectiveness of the licensees programs for transportation of radioactive materials. The focus of the inspection was on recently issued CRs documented for events related to the preparation and transportation of radioactive material.
4.2 Observations and Findings
a.
Hot work adjacent to combustibles The inspectors reviewed two contractor CRs (the contractors corrective action program is not a credited corrective action program) generated after hot work had caused the burning of Dry Active Waste (DAW). After the on-site inspection was completed, the inspectors reviewed one licensee AR generated after it was determined that hot work was again being performed contrary to procedural requirements. Based on the results of this review, the NRC inspectors identified one violation, with three examples, of NRC requirements.
Title 10 CFR 50.48(f) requires the licensee to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials. The licensees fire protection program implementing procedure SDS-FP1-PGM-0015, Control of Ignition Sources, revision 13, states in part:
1.
Section 4.1.7: Licensee must verify all Class A combustibles or Dry Active Waste bags within 35 feet of hot work have been removed or are shielded with approved welding curtains, welding blankets or welding pads.
2.
Section 4.1.9: Licensee must relocate combustibles a minimum of 5 feet from the side opposite work performed on metal walls.
Contrary to the above, the licensee failed to maintain the require standoff distance between ignition sources and combustible materials, as evidenced by the following three examples:
1.
Contrary to the section 4.1.9 above, on December 4, 2024, the licensee failed to maintain a 5-foot distance between hot metal surfaces and combustible materials which resulted in the burning of combustible materials. Specifically, the licensee contractors were welding shielding to a shipping container which contained DAW.
Contrary to licensee procedures, the DAW was not located greater than 5 feet from the hot area of the container. The heat from the welding burned the DAW. There were no flames observed, and the heat was extinguished immediately by the fire watch. CR SDS-002042 provided the following corrective actions: (a) examination of container contents prior to performing welding on containers; and (b) providing shielding on the interior of a container if the container includes flammable material.
2.
Contrary to the section 4.1.9 above, on January 20, 2025, the licensee failed to maintain a 5-foot distance between hot metal surfaces and combustible materials which resulted in the burning of combustible materials. Specifically, the licensee contractors were welding shielding to a shipping container which contained DAW.
The DAW was located greater than 5 feet from the hot areas of the container, however, during the welding, the DAW shifted into the hot area and the heat from the welding burned the DAW. There were no flames observed, and the heat was extinguished immediately by the fire watch. This event was documented in CR SDS-002057.
3.
Contrary to section 4.1.7 above, on February 6, 2025, the licensee failed to verify all Class A combustibles within 35 feet of hot work were removed or shielded with approved welding curtains, welding blankets or welding pad prior to the start of hot work. Specifically, combustible material was located approximately 10 feet from active torch cut work performed by a contractor. This resulted in sparks from the torch cut contacting the flammable material. An SCE observer identified the deficiency, and the combustibles were moved to an area greater than 35 feet away from the hot work. No fire or resulted from this event. This event was documented in AR 0225-70419.
Based on the continued events, the inspectors determined that the corrective actions taken were not adequate. On January 30, 2024, SCE issued AR 0125-77465 which states that the licensee will track action taken by the contractor to improve performance related to hot work as well as to track corrective action creation and implementation.
After the third hot work procedure violation on February 6, 2025, SCE issued a stop work order for all hot work activities while the above events and appropriate corrective actions are evaluated. (VIO 050-00362/2025-01-01; Failure to verify all combustibles had been removed when performing hot work)
b. Leaking Railcars The inspectors reviewed CR SDS-002048 generated after two railcars containing radioactive material were found leaking liquid from the bottom of the container after they were certified for shipment. Upon identification of the leaks, the containers were not permitted to leave the site. The containers were loaded with concrete and metal from building demolition. The licensee conducted radiation and contamination surveys and
verified no radioactive material had leaked out of the container. The licensee placed a hold on shipments, inspected similar railcars on site, and subsequently identified additional railcars with wet contents.
The inspectors reviews of documentation and interviews with personnel verified all required actions were performed in accordance licensee emergency procedure SDS-WM1-PCD-0003, Transportation Incident and Emergency Response Plan, revision 7.
The inspectors also verified the containers used for transport of the demolition debris were in accordance with Department of Transportation requirements for shipment of Limited Surface Activity material.
The inspectors observed corrective actions implemented after the leaking containers were investigated. The corrective actions included changes to the debris collection and increased oversight during loading to ensure liquid is minimized during loading of demolition debris. The inspectors observations, interviews, and record reviews validated the licensees corrective action program effectively identified and bounded the problem.
c.
Imbalanced Railcars The inspectors reviewed CR SDS-002054 generated after two railcars carrying radioactive material were stopped during transit by the rail company. The railcars transit was suspended after a railyard found the railcars had imbalanced loads. The licensees response was prompt, and they determined there were no radiological problems in addition to the imbalanced load. During the investigation, the licensee determined the railcar carrier caused the imbalance for both railcars. The licensee worked with the appropriate Agreement State and obtained the required mobile license with authorized personnel to correct the imbalance and allow the railcars to complete the shipment to the waste disposal site. The inspectors interviews, and record reviews validated the licensees corrective action program effectively assessed and responded the transportation event.
4.3 Conclusions The inspectors reviewed selected radioactive waste management and transportation activities and identified one violation of regulatory requirements. The violation involved the licensees failure to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials.
Exit Meeting Summary The inspectors presented the preliminary inspection results to Frederic Bailly, Vice President and Chief Nuclear Officer, and other members of the licensees staff at the conclusion of the onsite inspection on January 30, 2025. A final exit briefing was provided to the Vice President and Chief Nuclear Officer on February 11, 2025. 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, Manager, Project Management Office F. Bailly, SCE, Chief Nuclear Officer and Vice President Decommissioning J. Carey, SCE, Corrective Action Program Manager C. Cates, SCE, Manager, Prudency, Safety Culture and Employees Concern Program G. Ferrigno, SDS, Radiation Protection Manager T. Giard, SDS, D&D Project Director R. Kalman, SDS, Executive Sponsor T. Laursen, SDS, Corrective Action Program Manager J. Madigan, SCE, Manager, Radiation Protection and Waste Oversight; Nuclear Oversight S. Mannon, SDS, Programs Project Director/Regulatory Manager A. Martinez, SDS, Performance Improvement Manager M. Morgan, SCE, Manager, Regulatory Affairs L. Mosher, SCE, Manager, Communications J. Peattie, SCE, General Manager, Site Operations R. Pontes, SCE, General Manager, Site Closure and Environmental Oversight L. Rafner, SCE, Regulatory Affairs S. Seward, Audit Services Representative S. Sewell, SCE, Manager, Radiation Protection and Waste B. Sholler, SDS, LT/FSS Project Manager J. Stephenson, SCE, Manager, Engineering INSPECTION PROCEDURES USED IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors IP 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000362/2025-01-01 VIO Failure to verify all combustibles had been removed when performing hot work Closed None Discussed None
PARTIAL LIST OF DOCUMENTS REVIEWED Procedures SDS-FP1-PGM-0015, Control of Ignition Sources, revision 13 SDS-RP1-TSD-24-01, Open-Air Demolition Plan for San Onofre, revision 2 SDS-LT1-PCD-1008, Final Status Survey Isolation and Control Measures, revision 2 ENG-3, 10 CFR 50.59, 72.48, and 50.82 Program, revision 1 SDS-RA1-PGM-0002, 10 CFR 50.59 and 72.48 Program, revision 3 SDS-WM1-PCD-0003, Transportation Incident and Emergency Response Plan, revision 7 SDS-3-M-CO-2212, U3 RV (RLS) Reactor Lifting System Equipment Installation, revision 0 SDS-LT1-PCD-1008, Final Status Survey Isolation and Control Measures, revision 2 SDS-RP1-PGM-3000, Control of Radioactive Material, revision 5 SDS-RP1-PCD-3005, Portable Ventilation and the Use of Vacuum Cleaners, revision 9 SDS-QA1-PGM-0001, SONGS DecommissioningSolutions Quality Assurance Program, revision 5 Brandenburg MA0879-SONGS, Site-specific Health and Safety Plan, revision 12/30/2020 Condition Reports/Action Requests Reviewed SDS CR SDS-002042, December 4, 2024, Heat transfer through Conex, from welding, to DAW bag SDS CR SDS-002057, January 20, 2025, Transfer of heat from welding to a DAW bag inside ISO container SDS CR SDS-002048, December 1, 2025, Two railcars identified to be leaking from the bottom corners of floor SDS CR SDS-002054, January 15, 2025, SONGS railcar placed on Bad Order by United Pacific Open Air Demo Nightly Report, January 28, 2025 SCE AR 1024-49410, October 10, 2024, Undesirable conditions related to safety signs SCE AR 0225-70419, February 6, 2025, All combustibles not removed prior to performance of hot work Condition Reports/Action Requests Generated from Inspection SCE AR 0125-77465, January 30, 2025, Track and document actions taken by the contractor to improve performance specific to Hot Work SDS CR SDS-002062, January 30, 2025, Evaluate monthly inventory frequency and labeling for adequacy of in-service vacuums and HEPA ventilation units in accordance with SDS-RP1-PCD-3005 Licensing Bases Documents San Onofre Nuclear Generating Station Units 2 & 3 Defueled Safety Analysis Report (DSAR)
November 2024 Post-Shutdown Decommissioning Activities Report and Irradiated Fuel Management Plan dated May 7, 2022 Miscellaneous Radiation Work Permit 25-0-777 Signed Shipping Manifest LLRW-25-006, January 8, 2025 Signed Shipping Manifest LLRW-25-002, January 8, 2025 SONGS Hot Work Permit, January 20, 2025 SONGS Pre-Job Checklist/Post Job Brief, January 20, 2025 Calculation of Airborne Radioactivity Resulting from Smoldering Herculite, January 28, 2025
Open Air Demo Nightly Report dated January 28, 2025 SDS Daily ALARA Report dated January 29, 2025 Brandenburg Hot Work Permit MA0879, February 6, 2025 Safety Reviews, Design Changes, and Modifications SCE Applicability Determination, Screens and/or Evaluations for Elimination of Exclusion Area Boundary and Clarification of Site Boundary, 1220-99225-3, revision 0 SCE Engineering Change Package, NECP Number 1220-99225-4, Elimination of Exclusion Area Boundary (EAB) and Clarification of Site Boundary, revision 0 SCE Applicability Determination, Screens, and/or Evaluations for Install Protective Enclosures Over Beach Discharge Flaps, AR 1023-30925-6, revision 0 SCE Engineering Change Package, NECP Number 1023-30925-5, Install Protective Enclosures Over Beach Discharge Flap Valves, revision 0 SDS Applicability Determination, SDS-50.59-2023-0009, Abandon Sewage Treatment Plant and East/West Oily Waste Holding Sumps, revision N/A SDS Design Plan, Sewage Treatment Plant Isolation, revision 0 SDS Applicability Determination, SDS-50.59-2022-0005, LRW Mobile Processing & Discharge, revision 0 SDS Design Plan, LRW Mobile Processing & Discharge, revision 0 SONGS Calculation Package, SDS-EN1-CAL-0061m T-351 Tornado Missile Standard Review Plan 3.5 Review, revision 1 LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System ALARA As Low As Is Reasonably Achievable AR Action Request CFR Code of Federal Regulations CR Condition Report DAW Dry Active Waste DSAR Defueled Safety Analysis Report IP Inspection Procedure 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