IR 05000361/2025002

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NRC Inspection Report 05000361/2025002; 05000362/2025002
ML25085A371
Person / Time
Site: San Onofre  
Issue date: 03/31/2025
From: Jeffrey Josey
NRC/RGN-IV/DRSS/DIOR
To: Bailly F
Southern California Edison Co
McManus E
References
IR 2025002
Download: ML25085A371 (1)


Text

March 31, 2025

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2025-002; 050-00362/2025-002

Dear Frederic Bailly:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted onsite from March 10-13, 2025, 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 at the end of the onsite inspection on March 13, 2025. 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 decommissioning performance; occupational radiation exposure; and problem identification and resolution. 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 https://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:

Inspection Report 050-00361/2025-002; 050-00362/2025-002 w/Attachment: Supplemental Inspection Information Distribution via ListServ Signed by Josey, Jeffrey on 03/31/25 SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2025-002; 050-00362/2025-002 - DATED MARCH 31, 2025 DISTRIBUTION:

JMonninger, ORA JLara, ORA JGroom, DRSS NOKeefe, DRSS RAlexander, ORA DCylkowski, ORA VDricks, ORA TSmith, ORA AAlen-Arias, OEDO SAnderson, DRSS ASnyder, NMSS LWilkins, OCA AMoreno, RIV/OCA R4-DRSS-DIOR-DECOM DOCUMENT NAME: SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2025-002; 050-00362/2025-002 ADAMS A

REGION IV==

Docket Nos.

050-00361; 050-00362 License Nos.

NPF-10; NPF-15 Report Nos.

050-00361/2025-002; 050-00362/2025-002 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:

March 10-13, 2025 Exit Date:

March 13, 2025 Inspectors:

Robert J. Evans, PhD, PE, CHP, 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 Stephanie G. Anderson, Senior 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 050-00361/2025-002; 050-00362/2025-002 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.

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 Post-Shutdown Decommissioning Activities Report. The licensee maintained good radiological control over these work activities. The inspectors reviewed the status of a recently cited violation, and the violation was left open pending further investigation by the licensee. (Section 1.2)

Occupational Radiation Exposure at Permanently Shutdown Reactors

The licensee implemented the occupational radiation protection program in accordance with licensee procedures and applicable regulatory requirements. (Section 2.2)

Problem Identification and Resolution at Permanently Shutdown Reactors

The licensee and its decommissioning 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. (Section 3.2)

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 continued to prepare the rigging equipment inside Unit 3 containment for future lift and segmentation of the reactor vessel shell. In Unit 2 containment, the licensee continued to cut reactor vessel nozzles and remove interferences to facilitate future reactor vessel segmentation work. At the time of the inspection, the critical path work activities included open air demolition work. The material handling facility continued to be operational to support open air demolition of the site radioactive structures.

Decommissioning Performance and Status Reviews 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 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 licensee continued to conduct open air demolition. The Unit 2 and 3 radwaste buildings had been mostly demolished. The Unit 3 tank and penetration buildings were being demolished. The debris was being separated in the footprint of the former turbine buildings. The debris was being transferred to the adjacent material handling facility and loaded into railcars for offsite disposal. 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 3. The work was being conducted with an emphasis on industrial and radiological safety.

The inspectors attended meetings that included discussion of decommissioning activities as well as the current work 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.

The open-air demolition plan, Sections 5.0 through 8.0, provided instructions for daily environmental air sampling, workplace air sampling, contamination surveys, and dose rate surveys. The inspectors reviewed the results for the March 10, 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 removal of insulation from the upper portion of the external shell of the vessel. The licensee also continued to remove systems and interferences from the containment. The four reactor coolant pumps had been removed from Unit 2 containment and were staged for shipment for disposal.

In Unit 3, the major work activities included continued preparation for future cutting of the reactor vessel shell. During the inspection, the licensee had completed the load test of the reactor lifting system and was in the process of remotely inspecting the lifting configuration prior to reinstallation. This work was being accomplished in accordance with the written instructions provided in decommissioning work package SDS-3-M-CO-2212, Installation of the reactor vessel lifting equipment, revision 0. In addition, the licensee continued to cut and remove the remainder of the two steam generators from the containment building. All four reactor coolant pumps had been removed from containment and were previously shipped offsite for disposal.

The inspectors observed strong radiation protection support in both containments.

Housekeeping was adequate based on the work in progress. The inspectors conducted independent radiological surveys during site tours using a Thermo Scientific Radeye G survey meter (serial number 373, calibration due date of July 23, 2025, calibrated to cesium-137). Overall, the measured exposure rates were consistent with existing signs, boundaries, and postings.

c.

Problem Identification and Resolution The inspectors reviewed recently issued corrective action reports in this program area.

SDS Condition Reports (CRs) SDS-002065 and SDS-002067 documented the contractors discovery of rainwater inside of radioactive waste containers being stored outdoors. Temporary covers were previously used and were found to be ineffective at preventing rainwater from entering the containers. Immediate corrective actions included efforts to remove the water from the containers. Based on the available information, no container with free-standing liquid or leaking liquid had been shipped offsite.

On March 4, 2025, the Unit 3 containment crane accidently contacted the auxiliary bridge that was located over the reactor cavity. A stand-down order was issued to allow for inspection of the components and for review of the rigging processes. The inspectors attended a management review committee meeting on March 11, 2025. The committee discussed the event response plan and the draft apparent cause evaluation SDS-002072. The committee agreed to lift the stand-down order after completion of short-term corrective actions. Longer term corrective actions included a planned all-hands meeting, review of communications during rigging activities, and enhanced pre-job briefings. The licensee and its contractors corrective actions were determined to be appropriate for the level of risk involved.

In summary, the licensee and its decommissioning general contractor continued to identify and correct problems to facilitate the decommissioning project.

d.

(Discussed) Violation 050-00362/2025-01-01: Failure to verify all combustibles had been removed when performing hot work

During the January 2025 inspection (ML25045A210), the NRC identified a violation of 10 CFR 50.48(f) requirements with three examples. During this inspection, the inspectors reviewed the licensees early responses to the Notice of Violation. Recent corrective actions taken by the licensee included issuance of apparent cause evaluation report SDS-002057, dated February 19, 2025. The apparent cause evaluation included apparent and contributing causes of the three fire protection incidents. Since the licensees corrective actions and 30-day response to the NRC were incomplete at the close of the onsite inspection, the status of the licensees corrective actions will be reviewed during a future inspection.

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. The inspectors

reviewed the status of a recently cited violation, and the violation was left open pending further investigation by the licensee.

Occupational Radiation Exposure at Permanently Shutdown Reactors (IP 83750)

2.1 Inspection Scope To ensure adequate protection of worker health and safety from exposure to radiation or radioactive material and to evaluate whether the licensee adequately identified problems and implemented appropriate and timely corrective actions related to occupational radiation safety.

2.2 Observations and Findings a.

Radiological Work Planning and ObservationsSection II of the PSDAR states, in part, that appropriate radiological programs will be maintained throughout the decommissioning process to ensure radiological safety of the workforce is maintained. The licensee and its decommissioning contractor established and implemented radiological programs as required by 10 CFR Part 20.1101(a) and the PSDAR.

The inspectors performed tours of areas with radiological work in progress and areas where radioactive materials were stored. The inspectors conducted independent radiological surveys during site tours using a Thermo Scientific RadEye G survey meter (serial number 373, calibration due date of July 23, 2025, calibrated to cesium-137),

within both containments and outside the containments in the general areas where radioactive material is stored. The inspectors tours and procedure reviews validated radiological boundaries were properly posted to control access to radiation and high radiation areas in accordance with 10 CFR 20.1902 and procedure SDS-RP1-PCD-1005, Radiological Posting and Controls, revision 16. During the site tours, the inspectors also observed radioactive material stored both inside and outside containments to validate the material was correctly marked and labeled to ensure nearby personnel were informed of the exposure levels and validate the material was labeled in accordance with 10 CFR 20.1904 and procedure SDS-RP1-PCD-1002, Radioactive Material Container Labeling, revision 5.

During the inspectors observations of work to prepare the reactor vessel for segmentation in both Unit 2 and 3 containments, the inspectors validated the following:

all personnel wore required dosimetry correctly; Radiation Protection (RP) technicians provided continuous oversight and performed radiation surveys when appropriate; air samplers and powered air purifying respirators were in use during work. The inspectors observed RP technicians perform surveys and process personnel and materials exiting the high contamination area of the Unit 2 reactor vessel cavity. The work practices and surveys performed appeared effective to minimize the spread of contamination within the work area. The inspectors observed the operation of filtered ventilation systems used during highly contaminated work in the Unit 2 and 3 reactor cavities. The locations of the vent intakes appeared effective. Based on returns from lapel samples and the absence of personnel who have had radioactive intakes, the ventilation systems are effectively located and operated. All personnel observed demonstrated use of good health physics and performed work in accordance with licensee procedures.

Work performed in preparation of the Unit 2 reactor vessel segmentation was performed in areas near very high radiation levels. The inspectors noted the level of RP oversight, the performance of surveys, and urgency with which workers moved was aligned with the increased exposure risk and validated the licensee was maintaining exposure ALARA.

The inspectors reviewed the Open-Air Demo Nightly Report, dated March 10, 2025, to validate surveys and samples were performed in accordance with procedure SDS-RP1-TSD-24-01, Open-Air Demolition Plan for San Onofre, revision 3. The survey and sample results validated the contamination controls implemented are effective in preventing spread of contamination to uncontrolled areas.

The inspectors interviewed the SDS ALARA committee members regarding implementation of the ALARA program. In accordance with licensee procedure SDS-RP2-PGM-1000, Station ALARA Committee, revision 8, the ALARA committee meets to: evaluate radiological controls in RWPs, evaluate effectiveness of the work procedures in reducing exposure, determine and adjust exposure goals for the year, and review radiological performance trends. The ALARA committee held meetings at the frequency prescribed by the above procedure. Review of the SDS ALARA Annual Report 2024 validated that the ALARA program was successful in estimated exposure for the work to be performed in calendar year 2024; total exposure for calendar year 2024 was within 99% of the ALARA goal set for that year.

b.

Dosimetry The inspectors reviewed external and internal dosimetry program by review of records and interviews of the dosimetry manager and dosimetry engineer. No significant changes to the dosimetry program have occurred since the last inspection of this area.

The inspectors review validated dosimeters are stored, exchanged, and processed in accordance with licensee procedures. Discussion with dosimetry engineer and the inspectors observations of radiological work in Unit 2 containment validated correct placement of dosimeters for the work performed. The inspectors reviewed dose records for the highest individual exposures during calendar year 2024 and compared TLD returns with electronic personal dosimeter totals, no discrepancies were noted. The dosimetry manager maintains records to demonstrate personnel were monitored when required and exposure reports were documented and retained.

The inspectors reviewed use of portable air samplers and lapel samplers during work to monitor workers for unplanned intakes. The inspectors observations of work and review of records validated the licensee was ensuring adequate monitoring was used during work with the potential to generate airborne radioactivity conditions and monitoring was performed in accordance with licensee procedures. There were no recent records of bioassays were available for review as the licensee had no events requiring bioassays during the past 12 months.

c.

Special Dosimetric Situations The inspectors reviewed special dosimetry program by review of records and interviews of the dosimetry manager and dosimetry engineer. The inspectors discussed special dosimetric situations to evaluate how the licensee located worker dosimeters for non-

uniform fields. The licensee had no declared pregnancies in the past 12 months. The inspectors determined that the licensee is adequately following procedures and regulations to ensure personnel do not exceed dose limits.

d.

Problem Identification and Resolution The inspectors reviewed CRs issued since the last inspection of this program area.

The licensees problem identification and resolution programs have adequately identified, documented, and resolved deficient conditions in the area of occupational radiation exposure.

2.3 Conclusions The licensee implemented the occupational radiation protection program in accordance with licensee procedures and applicable regulatory requirements.

Problem Identification and Resolution at Permanently Shutdown Reactors (IP 40801)

3.1 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.

3.2 Observations and Findings a.

Corrective Action Programs Corrective action programs are required by 10 CFR Part 50, Appendix B, Criterion VXI and Section 16 of the licensees Decommissioning Quality Assurance Program (DQAP),

revision 11, 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 inspectors reviewed the details of the licensees corrective action program (CAP) in procedure ADM-5, Corrective Action Program, revision 6. Details of the contractors program were provided in procedure SDS-RA1-PGM-0005, SDS Corrective Action Program (CAP), revision 12. The inspectors reviewed multiple CRs and SCE Action Request to verify that the problems that have been identified, were corrected and that the corrective actions had a focus on preventing reoccurrence. Additionally, the inspectors interviewed both CAP managers about program trends, challenges faced, management engagement, and future for improvement and development items or plans.

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 licensee procedure NOD-2, Audit and Assessment Program, revision 7, and SDS procedure SDS-QA1-PCD-0011, Audit and Surveillance, revision 8. The inspectors reviewed the two audit and assessment programs and interviewed key staff to verify that the audit and surveillance programs were being implemented consistent with QA program requirements.

Based on the results of the interviews and document reviews, the licensee and its contractor continued to schedule and conduct audits and surveillances in their respective program areas. Schedules were developed to track the implementation of the required audits and surveillances. A review of selected audit and surveillance results indicated that the auditors continued to identify potential deficiencies and provide recommendations for improvement. In summary, both the licensee and its decommissioning contractor maintained adequate and regularly scheduled audit and surveillance programs.

c.

Safety Conscious Work Environment Regulatory Issue Summary 2005-18, Guidance for Establishing and Maintaining a Safety Conscious Work Environment, provides the NRCs guidance for establishing and maintaining safety-conscious work environments. In support of positive nuclear safety cultures, both the licensee and SDS established employee concerns programs. The licensees program was described in procedure ADM-2, Decommissioning Employee Concerns Program, revision 3, and SDSs program was described in procedure SDS-RA1-PGM-0004, Employee Concerns, revision 2. The inspectors conducted separate interviews of the two employee concern program managers, in part, to ensure that the two programs were effectively implemented per procedure requirements.

Both program managers were engaged with the work force and had regular and meaningful interactions with management. Both programs continued to receive concerns from site staff, and the program managers continued to follow up on these concerns.

Both program managers actively promoted the programs to ensure worker awareness.

In summary, the two programs were being implemented in accordance with procedural requirements.

d.

10 CFR Part 21 Processing Regulation 10 CFR Part 21 provides the reporting requirements for certain defects and failures. In response to this requirement, Section 6.15 of the SCE CAP procedure requires the licensee to screen external Part 21 reports for applicability to the site and follow up on responses to defects and failures identified at the site. The inspectors interviewed the licensees staff who managed the Part 21 program. The licensees staff continued to screen industry reports using SCE Action Request 0125-72463 to track and documented these reviews. No applicable 10 CFR Part 21 industry report was identified to be applicable to work being conducted at the site, and no defect or failures were identified at the site in calendar years 2024-2025.

3.3 Conclusions 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. The licensee continued to implement a program for identifying and processing of 10 CFR Part 21 defects and failures.

Exit Meeting Summary The inspectors presented the 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 March 13, 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 R. Besich, SCE, Chief Financial Officer M. Bryson, SCE, ISFSI Engineer J. Carey, SCE, Corrective Action Program Manager C. Cates, SCE, Manager, Prudency, Safety Culture and Employees Concern Program G. Ferrigno, SDS, Radiation Protection Manager J. Holt, SCE, Communications 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 J. Nowak, SDS, Executive Director/Sponsor J. Peattie, SCE, General Manager, Site Operations L. Rafner, SCE, Regulatory Affairs C. Samples, SCE, Contract Management Project Manager S. Seward, SCE, Corporate Auditing Service Representative S. Sewell, SCE, Manager, Radiation Protection and Waste INSPECTION PROCEDURES USED IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors IP 83750 Occupational Radiation Exposure at Permanently Shutdown Reactors IP 40801 Problem Identification and Resolution at Permanently Shutdown Reactors LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed 05000362/2025-01-01 VIO Failure to verify all combustibles had been removed when performing hot work

PARTIAL LIST OF DOCUMENTS REVIEWED Procedures ADM-2, Decommissioning Employees Concerns Program, revision 3 ADM-5, Corrective Action Program, revision 6 Decommissioning Quality Assurance Program (DQAP), revision 11 NOD-2, Audit and Assessment Program, revision 7 SDS-RA1-PGM-0005, SDS Corrective Action Program (CAP), revision 12 SDS-QA1-PGM-0001, SONGS DecommissioningSolutions Quality Assurance Program (SDS QAP), revision 5 SDS-QA1-PCD-0011, Audit and Surveillance, revision 8 SDS-PM1-PCD-0001, SDS Management Controls, revision 0 SDS-RP1-TSD-24-01, Open-Air Demolition Plan for San Onofre, revision 3 SDS-RP1-PCD-1005, Radiological Posting and Controls, revision 16 SDS-RP2-PGM-2000, Radiological Work Planning and Controls, revision 17 SDS-RP2-PGM-1000, Station ALARA Committee, revision 8 SDS-3-M-CO-2212, Installation of the reactor vessel lifting equipment, revision 0 Technical Documents Management Review Committee Meeting Package, ACE Charter for CR SDS-002072, March 11, 2025 Open Air Demo Nightly Report, March 10, 2025 Decommissioning Work Package SDS-3-M-CO-2212, Installation of the RV Lifting Equipment, revision 0 SDS Condition Reports SDS-001552 SDS-001707 SDS-001810 SDS-001924 SDS-002028 SDS-002072 SDS-001559 SDS-001714 SDS-001816 SDS-001926 SDS-002033 SDS-001592 SDS-001715 SDS-001827 SDS-001930 SDS-002036 SDS-001648 SDS-001721 SDS-001846 SDS-001945 SDS-002041 SDS-001651 SDS-001722 SDS-001850 SDS-001953 SDS-002043 SDS-001669 SDS-001732 SDS-001870 SDS-001971 SDS-002057 SDS-001673 SDS-001741 SDS-001880 SDS-001982 SDS-002059 SDS-001682 SDS-001749 SDS-001883 SDS-001988 SDS-002003 SDS-001686 SDS-001762 SDS-001892 SDS-001995 SDS-002028 SDS-001693 SDS-001779 SDS-001893 SDS-002000 SDS-002065 SDS-001696 SDS-001789 SDS-001896 SDS-002003 SDS-002067 SCE Action Requests 0123-98818 0323-97115 1023-25154 0624-87399 0924-73299 0125-72463 0223-10325 0523-41782 0224-93073 0624-15784 0624-31536 0323-62215 0823-61595 0424-61570 0924-94875 1124-82222 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 (PSDAR), May 7, 2020 Audits and Surveillances SCE 2025/2026 Nuclear Oversight Master Audit and Assessment Schedule, October 2024 SDS 2025 Audit and Surveillance Schedule, revision 0 Miscellaneous SDS ALARA Annual Report 2024 LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System ALARA As Low As Is Reasonably Achievable AR Action Request CAP Corrective Action Program CFR Code of Federal Regulations CR Condition Report DQAP Decommissioning Quality Assurance Program DSAR Defueled Safety Analysis Report IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation NRC Nuclear Regulatory Commission PSDAR Post-Shutdown Decommissioning Activities Report QA Quality Assurance QAP Quality Assurance Program RP Radiation Protection SCE Southern California Edison Company SDS SONGS Decommissioning Solutions SONGS San Onofre Nuclear Generating Station