IR 05000361/2025004
| ML25253A269 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/24/2025 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Bailly F Southern California Edison Co |
| References | |
| IR 2025004 | |
| Download: ML25253A269 (18) | |
Text
September 24, 2025
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-00361/2025-004; 050-00362/2025-004
Dear Frederic Bailly:
On July 7-10, 2025, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at your San Onofre Nuclear Generating Station, Units 2 and 3. On August 20, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
Based on the results of this inspection, the NRC has determined that three Severity Level IV violations of NRC requirements occurred. Because your staff placed the deficiencies into your corrective action program, the safety significance of the issues was determined to be low, and because the violations were non-repetitive and not willful, these violations are being treated as Non-Cited Violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy.
These NCVs are described in the subject inspection report. If you contest the violation(s) or significance of these NCVs, 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. (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedures, a copy of this letter, its enclosure(s), and your response will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs ADAMS, accessible from the NRC 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.
Sincerely, Jeffrey E. Josey, Branch Chief Decomm., ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket Nos. 05000361 and 05000362 License Nos. NPF-10 and NPF-15
Enclosures:
Inspection Report Nos. 050-00361/2025-004 and 050-00362/2025-004 w/Attachment: Document request sent to licensee prior to inspection date
Inspection Report
Docket Nos.
050-00361 and 050-00362
License Nos.
Report Nos.
050-00361/2025-004 and 050-00362/2025-004
Enterprise Identifier:
I-2025-004-0066
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:
July 7-10, 2025
Inspectors:
E. McManus, Health Physicist
S. Anderson, Senior Health Physicist
L. Gersey, Health Physicist
Accompanied By:
J. Josey, Chief
Approved By:
Jeffrey E. Josey, Chief
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
E-2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) conducted an announced, routine inspection of decommissioning activities in progress at the San Onofre Nuclear Generating Station, Units and 3 in San Clemente, California. Three Non-Cited Violations (NCVs) are documented in this inspection report.
List of Findings and Violations
Failure to control access to radioactive waste Report Section 03.01 Severity Level IV NCV 05000361/2025004-001 Opened/Closed IP 83750 Introduction: The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 37.11(c)(1) General Provisions, for the licensees failure to control access to radioactive waste.
Failure to lock doors to prevent unauthorized entry into an area that is accessible to personnel that has 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.
Report Section 03.01 Severity Level IV NCV 05000361/2025004-002 Opened/Closed IP 83750 Introduction: The inspectors identified a Severity Level IV Non-Cited Violation of licensee technical specification 5.8.2, Administrative Controls - High Radiation Area, for the licensees failure to lock doors to prevent unauthorized entry into an area that is accessible to personnel that has 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.
Failure to barricade and conspicuously post signage bearing the radiation symbol and words High Radiation Area Report Section 03.03 Severity Level IV NCV 05000361/2025004-003 Opened/Closed IP 83750 Introduction: Inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 20.1902(b), Posting Requirement, associated with the licensees failure to properly post a High Radiation Area.
Additional Tracking Items
None.
E-3 SITE STATUS Since the last inspection of the facility in May 2025 (ADAMS Accession No. ML25163A217), the licensee continued Unit 3 reactor vessel segmentation activity. In the Unit 2 containment, the licensee continued preparation for reactor vessel segmentation. In the areas external of the containment buildings, the licensee continued open air demolition of the Unit 3 fuel handling building and the Unit 2 radioactive waste tank farm. At the time of the inspection, the licensee was segmenting the Unit 3 reactor vessel. In Unit 2 containment, the licensee was preparing for the reactor vessel segmentation and completing steam generator segmentation. The material handling facility was operational for open air demolition of the site radioactive structures.
INSPECTION SCOPES
The inspection was conducted using the appropriate portions of the inspection procedures (IPs).
Currently approved IPs are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. The inspection was declared complete when the objectives of the IPs were met, consistent with Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program.
IP 71801 - Decommissioning Implementation and Status Status of Decommissioning (IP Section 03.01)
The inspectors assessed the status and conduct of facility decommissioning in progress by:
- (1) Participation in the daily SONGS Decommissioning Solutions (SDS) plan of the day meeting which discussed daily work activities
- (2) Interviewing SDS senior management on the upcoming project schedule IP 64704 - Decommissioning Fire Protection Program Fire Protection Program (IP Section 03.01)
The inspectors verified compliance with the administrative portions of the licenses fire protection program. The inspectors:
- (1) Interviewed fire protection personnel
- (2) Reviewed procedure SDS-FP1-PMG-001, SDS Fire Protection Program, revision 11
- (3) Reviewed San Onofre 2&3 Defueled Fire Hazard Analysis, SDS-EN3-FHA-2/3-3.0, revision 2
- (4) Reviewed procedure SDS-FP1-PCD-005, Inspection and Control of Combustibles and Transient Fire Loads Within the Units 2 & 3 Industrial Area, revision 10
- (5) Reviewed procedure SDS-FP1-PCD-0015, Control of Ignition Sources, revision 18
- (6) Reviewed procedure SDS-FP1-PCD-0016, Portable Fire Extinguisher and Fire Safety Inspections, revision 13
E-4 Fire Area Walkdown and Work Observations (IP Section 03.02)
The inspectors conducted plant walkdowns of select fire areas, observed work activities, and reviewed the site training program for individuals who maintain fire watch qualifications.
Specifically, the inspectors:
- (1) Toured Units 2 and 3 containment buildings and deconstruction areas
- (2) Toured the material handling facility
- (3) Observed Unit 3 reactor vessel segmentation hot work activities
- (4) Observed Unit 2 turbine building basement hot work activities
- (5) Reviewed training records for several fire watch personnel
- (6) Reviewed the Memorandum of Agreement Between Southern California Edison Company and Marine Corps Installations West-Marine Corps Base, Camp Pendleton, dated July 13, 2020
- (7) Reviewed annual fire drill records Verification of the Fire Protection Systems and Equipment (IP Section 03.03)
The inspectors inspected portable fire extinguishers to verify they had been inspected annually by the State Fire Marshal and verify they had been inspected monthly by licensee personnel in accordance with licensee Pre-Fire Plans and procedure SDS-FP1-PCD-0016, Portable Fire Extinguisher and Fire Safety Inspections, revision 13. The areas where fire extinguishers were inspected included:
- (1) Units 2 and 3 containment buildings
- (2) Units 2 and 3 deconstruction areas
- (3) Material handling facility Problem Identification and Resolution (IP Section 03.04)
The inspectors reviewed and discussed the following CRs with licensee personnel:
- (1) CR SDS-001979
- (2) CR SDS-002078 IP 83750 - Decommissioning Occupational Radiation Control Radiological Work Planning and Execution (IP Section 03.01)
The inspectors verified the licensee was identifying and assessing the magnitude and extent of radiological hazards and was adequately implementing radiological controls during planning and execution of radiological work. The inspectors:
- (1) Toured the Unit 2 and Unit 3 containment buildings to observe posting and control of high radiation areas, negative ventilation operation, and storage and marking of radioactive material
- (2) Toured the 10 CFR Part 37 restricted areas to verify adequate implementation of access controls.
- (3) Toured radioactive material storage areas adjacent and external to the containment buildings to observe adequate packaging, marking, and control of access to material
E-5
- (4) Toured the material handling facility to observe waste loading operations and implementation of airborne radioactivity contamination control
- (5) Observed radiation protection (RP) technicians perform radiation surveys while adding shielding to shipping containers and observed RP technicians perform surveys on a shipping container after identification of a label discrepancy to verify compliance with procedure SDS-RP1-PDC-1001, Radiological Surveys, revision 24
- (6) Reviewed Radiation Work Permits for work observed in radiologically controlled areas to verify compliance with procedure SDS-RP2-PGM-2000, Radiological Work planning and Controls, revision 17
- (7) Reviewed ALARA Work Plans and SDS daily ALARA Report for work with higher radiation exposure risk
- (8) Reviewed Procedure SDS-RP1-PCD-1005 Attachment 5.12, HRA/LHRA Inventory, dated June 26, 2025, to verify licensee is controlling and tracking High Radiation Areas and Locked High Radiation Areas
- (9) Reviewed Procedure SDS-RP1-PCD-1005, Radiological Posting and Controls, revision 17, to verify licensee implemented adequate procedures to control access to areas with higher radiation levels
- (10) Reviewed Procedure SDS-RP1-PGM-1000, Radiation Protection Program, revision 16, to validate adequate implementation of 10 CFR 19 and 20 regulations Occupational Radiation Exposure Topical Areas (IP Section 03.02)
The inspectors verified the licensee is implementing a risk informed approach to the tracking and management of occupational exposure. The inspectors:
- (1) Observed operation of the temporary ventilation system in Unit 2 containment and the material handling facility to verify system is used when required and the intake location adequate
- (2) Observed the operation of continuous air monitors in Unit 2 and Unit 3 containments to verify are operating and are within calibration
- (3) Observed work with the potential for airborne radioactivity in the Unit 3 containment and in the turbine building basin to verify use of positive air pressure respirators
- (4) Observed personnel and material contamination monitoring at the Unit 2 and Unit 3 control point areas
- (5) Observed RP technician instrument use during personnel monitoring when personnel exited the material handling facility and the waste storage areas adjacent to the containment buildings
- (6) Interviewed the dosimetry program manager. The discussion included the dosimetry return records, bioassay program, and special dosimetry procedures for declared pregnancies and for work in non-uniform radiation fields.
- (7) Interviewed As Low As Reasonably Achievable (ALARA) manager and discussed use of portable air sampler and lapel sampler data for dose assessments.
- (8) Verified the National Voluntary Laboratory Accreditation Program certification for the licensees dosimetry processor.
- (9) Reviewed the Total Dose Summary Report for calendar year 2024, dated June 30, 2025, and the RWP Total Dose reports for Unit 3 steam generator primary and secondary side segmentation
E-6
- (10) Review of records for personnel contamination events during calendar year 2025 and discussion with RP management about procedures for personnel contamination events
- (11) Reviewed Open Air Demo Nightly Report generated on July 8, 2025, to validate effective monitoring and control of airborne exposure during demolition work
- (12) Reviewed Source Term Assessment for San Onofre (August 2021) and discussed the assessment with the ALARA management group
- (13) Reviewed Report of Dose Extensions for Active Employees, dated July 08, 2025, and 2025 Report for High Dose Individuals by TEDE, dated July 08, 2025, to verify the licensee is managing exposure adequately Problem Identification and Resolution (IP Section 03.03)
The inspectors reviewed the current list of ARs and CRs. The following records were discussed with the RP management and Southern California Edison (SCE) and SDS regulatory affairs managers:
- (1) CR SDS-002154
- (2) CR SDS-002161
- (3) Apparent Cause Evaluation Report - CR# SDS-002161, Unposted High Radiation Area, August 6, 2025 IP 85103 - Material Control and Accounting at Decommissioning Nuclear Power Reactors MC&A Programs and Procedures (IP Section 02.01)
The inspectors reviewed the licensees approved material control and accounting (MC&A)related procedures including personnel duties and responsibilities. The inspectors:
- (1) Examined the licensees procedure for implementation of the MC&A program
- (2) Interviewed licensee personnel regarding implementation of the MC&A program for control of special nuclear material (SNM) material Physical Inventory of SNM (IP Section 02.03)
The inspectors reviewed the licensees physical inventory program. The inspectors:
- (1) Reviewed the licensees program for physical inventories of SNM, including the inventories for the last three years
- (2) Reviewed the licensees physical inventory procedures and practices including physical observation of each item inventoried
- (3) Toured areas where SNM was being stored SNM Material Status and Transaction Reports (IP Section 02.04)
The inspectors reviewed the licensees required reports to the national Nuclear Materials Management and Safeguards System. The inspectors:
- (1) Reviewed selected records of reports submitted to the NRC
- (2) Interviewed licensee personnel responsible for submitting required reports to the NRC
E-7
INSPECTION RESULTS
Failure to control access to radioactive waste Report Section 03.01 Severity Level IV NCV 05000361/2025004-001 Opened/Closed IP 83750
Introduction:
The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 37.11(c)(1) General Provisions, for the licensees failure to control access to radioactive waste.
Description:
During a site tour, inspectors identified that a door serving as a barrier around a radioactive material storage area was not locked at all times as required. The licensee was notified, and guards were posted at the door. During follow-up discussions, the licensee maintained that the door could not be opened from the outside and was therefore adequate.
Inspectors verified through additional observations and interviews that the door could be opened and therefore was inadequate as a barrier.
Inspectors determined that during certain periods access to radioactive waste was not controlled in accordance with 10 CFR 37.11(c)(1).
Corrective Actions: Licensee posted security personnel to provide direct observation and control access until the door was permanently modified to correct the barrier vulnerability.
Corrective Action References:
CR SDS-002186 Action Request (AR) 0725-61258
Analysis:
The licensee had installed a door which did not meet the requirements. Although the door was not sufficient to prevent unauthorized access to the area, no unauthorized entry occurred. The door had an electronic monitoring system in place to immediately notify security if unauthorized access had occurred.
Enforcement:
Severity: This finding was determined to be a Severity Level IV, Non-Cited Violation, consistent with IMC 0609, Appendix D, Figure 6, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material. Per Figure 6, this violation screens to green (SLIV) as there was a failure of a barrier, but not an inability to monitor and detect unauthorized access.
Violation: 10 CFR 37.11(c)(1) states, in part, a licensee that possesses radioactive waste that contains category 1 or category 2 quantities of radioactive material shall use continuous physical barriers that allow access to the radioactive waste only through established access control points.
Contrary to the above, from August 5, 2021 - July 10, 2025, the licensee failed to use a continuous physical barrier that allows access to radioactive waste only through established access control points. Specifically, the door could be moved, which would allow unauthorized personnel access to the radioactive waste.
Enforcement Action: This violation is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.
E-8 Failure to lock doors to prevent unauthorized entry into an area that is accessible to personnel that has 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.
Report Section 03.01 Severity Level IV NCV 05000361/2025004-002 Opened/Closed IP 83750
Introduction:
The inspectors identified a Severity Level IV Non-Cited Violation of licensee technical specification 5.8.2, Administrative Controls - High Radiation Area, for the licensees failure to lock doors to prevent unauthorized entry into an area that is accessible to personnel that has 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.
Description:
Inspectors review of CR SDS-002154 indicated that during the period from May 16-19, 2025, the Unit 2 containment building contained radioactive material with 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 radiation. As such, this radioactive material required control as a Locked High Radiation Area (LHRA) in accordance with licensee technical specification 5.8.2. During this time, the Unit 2 containment building hatch panel doors were utilized as part of the LHRA barrier to control access to the material. The containment building hatch panel door included a personnel access door with a locking device.
Inspectors noted that technical specification 5.8.2 states, in part, that LHRAs shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control.
Inspectors determined that the Unit 2 containment personnel access door was not adequate to serve as a LHRA barrier because the Unit 2 containment building hatch panel door, could be moved which would render the locking device on the personnel access door ineffective. In this condition, the LHRA was not controlled in accordance with licensee technical specification 5.8.2.
Inspectors determined that during the period from May 16-19, 2025, access to the LHRA was not properly controlled in accordance with technical specifications.
Prior to the inspectors arrival for this inspection, the LHRA boundary had been reduced to the immediate area surrounding material requiring LHRA controls and the Unit 2 containment building hatch panel door was no longer being utilized as an LHRA barrier.
Corrective Actions: No corrective actions were taken; the condition no longer existed when this inspection was conducted.
Corrective Action References:
CR SDS-002186 AR 0725-61258
Analysis:
There was a potential for personnel to receive exposure to a dose rate which would cause them to exceed the regulatory limit within a short period of time because the Unit 2 containment building hatch panel door was an ineffective barrier during the period it was part of the barrier utilized to control access to an LHRA. However, there was no unauthorized access to the LHRA. The Unit 2 containment building hatch panel doors had an electronic monitoring system installed which would have alerted site security personnel in the event of an unauthorized access.
E-9
Enforcement:
Severity: This finding was determined to be a Severity Level IV, Non-Cited Violation, consistent with NRCs Enforcement Policy, dated August 12, 2025, as informed by materials operations example 6.3.d.3, in which a licensee failed to implement a procedure.
Violation: Technical specification 5.8.2 states, in part, areas that are 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, or from any surface penetrated by the radiation, shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the shift manager on duty, RP supervisor, or his or her designee. Technical Specification 5.8.2 further states that doors shall remain locked except during periods of access by personnel under an approved RWP or equivalent that specifies the dose rates in the immediate work areas and the maximum allowable stay time for individuals in that area.
Contrary to the above, from May 16-19, 2025, the licensee failed to lock doors to prevent unauthorized entry into an area that is accessible to personnel that has 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, the design of the Unit 2 containment building hatch panel door was not sufficient to prevent unauthorized access.
Enforcement Action: This violation is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
Failure to barricade and conspicuously post signage bearing the radiation symbol and words High Radiation Area (HRA)
Report Section 03.03 Severity Level IV NCV 05000361/2025004-003 Opened/Closed IP 83750
Introduction:
Inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 20.1902(b), Posting Requirement, associated with the licensees failure to properly post a High Radiation Area.
Description:
Prior to the inspectors arrival on site, the licensee notified the NRC that an HRA was not controlled in accordance with regulations and licensee procedures.
On May 27, 2025, an operator entered Unit 2 Refueling Water Storage Tank (RWST) T006 vault on a Radiation Work Permit task that was for a Radiation Area (RA). The setpoints on his personal electronic dosimeter (PED) were 20 millirem dose and 80 millirem per hour dose rate. As the operator approached the area where he needed to operate a valve, he received a PED dose rate alarm, and he left the area immediately.
The RP surveys performed after the PED dose rate alarm identified that Unit 2 RWST T006 vault contained two HRAs around two drums with respective radiation dose rates of 407 and 454 millirem per hour at 30 centimeters.
The areas were not posted a HRAs as required by 10 CFR 20.1902(b) and licensee procedure SDS-RP1-PCD-1005, Radiological Posting and Controls, Section 3.1.15, revision 17. The licensees investigation determined that the area had previously been posted as a HRA and an RP technician incorrectly downgraded the HRA to an RA. That condition existed for approximately eight days in May 2025. Further analysis of the operators radiation
E-10 exposure indicated the maximum dose received was 0.3 millirem, which was under regulatory limits. No health impact to the operator is expected.
The licensees Apparent Cause Evaluation determined the causes to be
- (1) an RP technicians failure to perform work in accordance with RP procedures and the RP technicians failure to determine an HRA posting was required, and
- (2) a supervisory RP technician that did not demonstrate an adequate questioning attitude, situational awareness, and control of the conditions present in the Unit 2 RWST T006 vault.
Corrective Actions: The Unit 2 RWST T006 vault was surveyed, barricaded and posted as required. The RP technician was removed from duties, and the Supervisory RP technician was counselled and retrained. An Apparent Cause Evaluation was completed. RP fundamentals gap training was provided to RP technicians who had no prior RP experience before employment at SONGS.
Corrective Action References:
CR SDS-002161 AR 0525-28005 Apparent Cause Evaluation Report - CR# SDS-002161
Analysis:
There was not a substantial potential for exposure in excess of the applicable dose limits because the worker was wearing a PED. The operators whole body did not enter the HRA Field.
Enforcement:
Severity: This finding was determined to be a Severity Level IV, Non-Cited Violation, consistent with NRCs Enforcement Policy, dated August 12, 2025, as informed by materials operations example 6.3.d.3, in which a licensee failed to implement a procedure.
Violation: 10 CFR 20.1902(b) requires, that the licensee post each High Radiation Area with a conspicuous sign or signs bearing the radiation symbol and the words CAUTION, HIGH RADIATION AREA or DANGER, HIGH RADIATION AREA. Licensee procedure SDS-RP1-PCD-1005, Radiological Postings and Controls, revision 17, step 4.7.5. requires that each HRA is barricaded and conspicuously posted with signage bearing the radiation symbol and words: Caution or Danger High Radiation Area. An HRA is an accessible area in which radiation levels could result in an individual receiving a deep dose equivalent in excess of 100 millirem in one hour at 30 centimeters from the radiation source or 30 centimeters from any surface that the radiation penetrates.
Contrary to the above, between May 19-27, 2025, the licensee failed to barricade and conspicuously post signage bearing the radiation symbol and words High Radiation Area.
Specifically, within the Unit 2 RWST T006 vault two radioactive waste drums with radiation dose rates of 407 and 454 millirem per hour at 30 centimeters were located in an area posted as a Radiation Area.
Enforcement Action: This violation is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
EXIT MEETING/DEBRIEFS The inspectors verified that no proprietary information was retained or documented in this report.
E-11
- On July 10, 2025, the inspectors presented the routine preliminary inspection results to Frederic Bailly, Vice President and other members of the licensees staff.
- On August 20, 2025, the inspectors presented the final exit meeting to Frederic Bailly, Vice President and other members of the licensees staff.
DOCUMENTS REVIEWED
Additional Documents Reviewed:
Type
Designation
Title or Description
Revision
or Date
Radiation
Protection
SDS-RP4-PCD-
2001 Attachment
5.5
Source Inventory/Verification
May 2021
Radiation
Protection
SDS-RP1-PCD-
3004
Receipt of Radioactive Material
Radiation
Protection
SDS-RP1-PCD-
3002
Surveys for Release of Liquids, Sludges,
Slurries, and Sands
Radiation
Protection
SDS-RP1-PGM-
4000
General Employee Radiation Worker
Training Program Description
Radiation
Protection
SDS-RP1-PGM-
4000
General Employee Radiation Worker
Training Program Description
Radiation
Protection
N/A
July 07,
25
Radiation
Protection
ALARA Work Plan
25-2-619
improvement 2
Surgical demo of U2 tank bldg and tanks
Radiation
Protection
ALARA Work Plan
25-2-842
Supplemental 2
Perform U2 Under Reactor Vessel
Insulation removal and prep Work
Radiation
Protection
ALARA Work Plan
25-2-842
Supplemental 2
Perform U2 Under Reactor Vessel
Insulation removal and prep Work
Radiation
Protection
Radiation Work
Permit 25-0-700
Routine Visual Inspections, Tours, and
Walkdowns
Radiation
Protection
Radiation Work
Permit 25-2-619
Perform Surgical removal of plant
systems, and components in U2 Tanks
and tank bldg area. All associated work.
All associated groups
Radiation
Protection
Radiation Work
Permit 25-0-300
Routine Operations Work. All associated
work. All work groups
Fire
Protection
SDS-RP1-TSD-
20-01
Fire Dose Calculation for SONGS
Fire
Protection
SDS-EN3-FHA-
0015
Deletion of Exclusion Area Boundary and
Implementation of Site Boundary for
Meeting Offsite Dose Requirements
Fire
Protection
SDS-EN3-FHA-
20
East Loop Fire Main Isolation
2/3-Key Plan
December
20, 2023
E-12
Fire
Protection
SDS-OP1-DWG-
Units 2/3 Key Plan Pre-Fire Plans
Fire
Protection
SDS-OP1-DWG-
PFP 2-001
Unit 2 Containment Elevation 15 to 30,
Pre-Fire Plans
Fire
Protection
SDS-OP1-DWG-
PFP 2-001
Unit 2 Containment Elevation 45 to 80,
Pre-Fire Plans
Fire
Protection
SDS-OP1-DWG-
PFP 2-012
North Yard Area Elevation 30 (Grade),
Pre-Fire Plans
Fire
Protection
SDS-OP1-DWG-
PFP 3-033
Unit 3 Containment Elevation 15 to 30,
Pre-Fire Plans
Fire
Protection
SDS-OP1-DWG-
PFP 3-033A
Unit 3 Containment Elevation 45 to 80,
Pre-Fire Plans, revision
Fire
Protection
SDS-OP1-DWG-
PFP Introduction
SDE Pre-Fire Plan Strategies for SONGS
Fire
Protection
SDS-RA1-FASA-
25-01
Fire Protection Program Assessment -
Corrective Action Item EH-1 from ACE
SDS-002057, Transfer of Heat from
Welding to a DAW Bag Inside ISO
Container
April 14,
25
Fire
Protection
23 Radiation
Protection
Fire Response & Contaminated Injury Drill
Scenario Manual
February
21, 2023
Waste
Management
Package ID: SDS-
2308
Package Listing for container SDS-02308
July 7,
25
Waste
Management
Package ID: SDS-
2309
Package Listing for container SDS-02309
July 7,
25
Waste
Management
Package ID: SDS-
2310
Package Listing for container SDS-02310
July 7,
25
Radioactive
waste
Memo 21-152-004
Q-Code 115 Review of Characterization
Analysis
May 19,
25
Documents Received not Reviewed:
Type
Designation
Title or Description
Revision
or Date
Fire
Protection
SDS-OP1-
DWG-PFP 1-
001
ISFSI, North Industrial Area, OCA Elevation
to 20, Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP 1-
001
NIA/ISFSI Area Building: ISFSI Security
Elevation 20, Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP 2/3-
030
Railroad Access Elevation 30, Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP 2-11
Unit 2 AFW Pump Room, AFW Pipe Tunnel,
Refueling Water and Condensate Storage
Tanks Elevation (-)26 to 306. Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP 3-
043
Unit 3 AFW Pump Room, AFW Pipe Tunnel,
Refueling Water and Condensate Storage
E-13
Tanks Elevation (-) 2 6 to 30 6. Pre-Fire
Plans
Fire
Protection
SDS-OP1-
DWG-PFP
Appendix A SH
ISFSI/North Industrial Area/OCA Fire Hydrant
and Post Indicator Valve Location
Fire
Protection
SDS-OP1-
DWG-PFP
Appendix A SH 2, Units 2/3 Fire Hydrant and
Post Indicator Valve Location
Fire
Protection
SDS-OP1-
DWG-PFP
Appendix A SH
South OCA Fire Hydrant and Post Indicator
Valve Location
Fire
Protection
SDS-OP1-
DWG-PFP
North OCA Key
Plan
North Owner Controlled Area Key Plan
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-003
T-10 (South Yard Facility) Partial First Floor
(North End) Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-003A
T-10 (South Yard Facility) Partial First Floor
(South End) Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-003B
T-10 (South Yard Facility) Second Floor (North
End) Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-004A
South Yard Facility Hazardous Waste Storage
Area Elevation 1068 Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-004B
South Yard Area Elevation 106 8 Pre-Fire
Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-005
Mud Control Room/Microwave Building
Elevation 117 Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-006
OCA Building A-80, A-81, A-82 Elevation 14
to 20 Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-009
OCA Building L-50 Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-010
OCA Lot 4 Trailer Complex Elevation 966
Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
OCA-010A
OCA Reservoir SDS Trailer Complex
Elevation 96 6 Pre-Fire Plans
Fire
Protection
SDS-OP1-
DWG-PFP
South OCA Key
Plan
South Owner Controlled Area Key Area
E-14
Fire
Protection
SDS-OP1-
DWG-PFP YD-
056
Switch Yard Elevation 30 to 78
Condition Reports and Action Requests Reviewed
AR 0125-72093
AR 0425-52284
AR 0425-85687
AR 0524-16129
AR 0525-80369
AR 0725-61258
AR 0725-47773
AR 0725-31956
CR SDS-001907
CR SDS-002118
CR SDS-002144
CR SDS-002089
CR SDS-002101
CR SDS-002106
CR SDS-002010
CR SDS-002003
CR SDS-002001
CR SDS-001988
CR SDS-001914
CR SDS-001896
CR SDS-001892
CR SDS-001891
CR SDS-002120
CR SDS-001891
CR SDS-002182
CR SDS-002154
CR SDS-002186
CR SDS-002181
CR SDS-001945
CR SDS-002063
CR SDS-002078
CR SDS-002118
ATTACHMENT
Document request sent to licensee prior to inspection date
The following items are requested for upcoming inspection
at San Onofre Units 2 & 3
July 7-10, 2025
Inspection Report 2025-004
Inspection Procedures:
1.
IP 71801, Decommissioning Performance and Status Reviews at Permanently Shutdown
Reactors
2.
IP 64704, Fire Protection Program at Permanently Shutdown Reactors
3.
IP 83750, Occupational Radiation Exposure at Permanently Shutdown Reactors
4.
IP 85103, Material Control and Accounting at Decommissioning Nuclear Power Reactors
Please have the requested information available and uploaded into BOX by Friday, June
27, 2025.
Inspectors:
Stephanie Anderson, Lead, Senior Health Physicist
Linda Gersey, Health Physicist
Eric McManus, Health Physicist
If there are any questions, please contact Eric McManus, 808-265-1878,
eric.mcmanus@nrc.gov
1.
IP 71801, Decommissioning Performance and Status Reviews at Permanently
Shutdown Reactors
A. Updated organizational charts for SCE and SDS
B. High level SDS and D&D Schedule of Activities
C. Updated documents if revised:
1.
Surgical Demo Plan SDS-RP1-TSD-21-08, Rev 4
2.
Open Air Demo Plan SDS-RP1-TSD-24-01, Rev 3
3.
DQAP, Rev 10
4.
ODCM, Rev 19
D. Apparent Cause Evaluations & Root Cause Evaluations since last inspection
E. DTF expenditures
The activities to be observed will depend on the work in progress at the time of the
inspection, thus, these records will be requested at the time of the inspection.
2.
IP 64704, Fire Protection Program at Permanently Shutdown Reactors
A. Copies of fire protection design basis documents
B. Copy of the Fire Protection Program Procedure
C. Copy of the Defueled Fire Hazard Analysis Report
- D. Copies of Fire Brigade staffing, Pre-fire Plans, and Procedures for Firefighting
E. Copies of agreements with local offsite fire department
F. List of current fire protection systems and features impairments
G. Copies of any self-assessments/audits performed which included fire protection
H. List of CRs/ARs related to fire protection since July 2024
3.
IP 83750, Occupational Radiation Exposure at Permanently Shutdown Reactors
- A. Copy of Annual Exposure Results for 2024, TLD and Electronic Dosimetry, and 2025
dose up to date.
B. Last 3 ALARA Committee meeting minutes
- C. List of locations for any HRAs, VHRAs, LHRAs at the facility
D. Copies of the following SDS Procedures (if any of these procedures apply to SCE
please also provide)
1.
ALARA Program
2.
Internal Dosimetry Program External Dosimetry Program
3.
Radiation Surveys and/or Routine Surveys
4.
Air Sample Collection and analysisContamination survey including alpha
monitoring and hard-to-detect isotopes
5.
Surveying and Releasing of Material from an RCA for unrestricted use.
6.
Radiological Posting, labelling, and marking
E. Copies of Audits and Self-Assessments of the ALARA and Exposure Monitoring
programs/ Radiation Protection Programs since April 2024
G. Exposure budget for 2025
H. List of Radiation Work Permits that have been generated for 2025
- I.
List of CRs/ARs since April 2024 related to radiation protection (ex. DosimetryProperty "Contact" (as page type) with input value "I.</br></br>List of CRs/ARs since April 2024 related to radiation protection (ex. Dosimetry" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,
radiation worker practices, respiratory protection, etc.)
- J.
Current evaluation of source termProperty "Contact" (as page type) with input value "J.</br></br>Current evaluation of source term" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., including alpha/beta gamma ratios
K. NVLAP accreditation certificates for required categories
L.
Inventory record for sealed sources
4.
IP 85103, Material Control and Accounting at Decommissioning Nuclear Power
Reactors
a.
Organization Charts with MC&A functions; personnel responsible for SNM, fuel
and non-fuel and their phone numbers
b.
All MC&A and MC&A related procedures, including:
1.
Overall content of SNM
2.
Physical Inventory
3.
Oversight of Contractors
4.
Movement of Non-Fuel SNM
c.
Records of the physical inventories since July 2022.
d.
SNM-MC&A Audits, Assessment, & Corrective Actions Documents since July
22.
e.
All reconstitution and fuel failure records, including final disposition of the
orphaned rods and rod pieces.
f.
SNM Material Status and Transaction Reports (DOE/NRC Forms 741/742) since
July 2022.