IR 05000361/2016001
| ML16216A364 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/03/2016 |
| From: | Rachel Browder, Whitten J NRC/RGN-IV/DNMS/RSFSB |
| To: | Thomas J. Palmisano Southern California Edison Co |
| Whitten J | |
| References | |
| IR 2016001 | |
| Download: ML16216A364 (42) | |
Text
ust 3, 2016
SUBJECT:
ERRATA TO SAN ONOFRE NUCLEAR GENERATING STATION -
NRC INSPECTION REPORTS 05000361/2016001; 05000362/2016001; AND 07200041/2016001
Dear Mr. Palmisano:
The U.S. Nuclear Regulatory Commission (NRC) has identified errors in NRC Inspection Report Nos. 05000361/2016001, 05000362/2016001, and 07200041/2016001 dated May 5, 2016 (ADAMS Accession No. ML16127A580). Specifically, the report incorrectly identifies the license amendment request letter dated August 20, 2015, and the Post-Shutdown Decommissioning Activities Report (PSDAR) dated September 23, 2014, as commitment documents to the NRC.
These two documents are not considered regulatory commitments to the NRC.
The license amendment request is approved through issuance of amendments to the San Onofre Nuclear Generating Station (SONGS) operating license. In this case, Amendment No. 233 to Facility Operating License No. NPF-10 and Amendment No. 226 to Facility Operating License No. NPF-15 and the associated Technical Specifications for Units 2 and 3, respectively, were revised in response to the license amendment request letter dated August 20, 2015, and as supplemented by letters dated November 19, 2015, and January 12, 2016 (ADAMS Accession Nos. ML15236A018, ML15327A410, and ML16014A376, respectively).
The revisions to the Technical Specifications are considered regulatory requirements, but not specifically the license amendment request letter itself. The approved Technical Specification changes allowed for the licensee to revise the Updated Final Safety Analysis Report (UFSAR)
to reflect the significant reduction of decay heat loads in the SONGS Units 2 and 3 spent fuel pools resulting from the time that has elapsed since the permanent shutdown of the units in 2012. The revisions support design basis changes associated with implementing the cold and dark plant status described in the PSDAR.
The PSDAR is required to be submitted to the NRC under 10 CFR 50.82(a)(4) and the licensee is required to keep it updated. Since the PSDAR is not required to be approved by the NRC, then it is not recognized as a regulatory commitment to the NRC. Further, if the licensee decides to change its direction from what is stated in the PSDAR, then the licensee shall notify the NRC in accordance with 10 CFR 50.82(a)(7). The NRC has reissued the applicable pages of the report to correct this error. Please replace the pages 5, 7, 10, and 20 of the inspection report with the attached corrected pages.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Jack E. Whitten, Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Docket Nos. 50-361; 50-362; and 72-41 License Nos. NPF-10; NPF-15 Enclosure:
Inspection Report 05000361/2016001; 05000362/2016001; 07200041/2016001 w/Attachment: Supplemental Information
REPORT DETAILS Site Status On June 12, 2013, Southern California Edison (SCE), the licensee, formally notified the NRC by letter that it had permanently ceased power operations at Units 2 and 3, effective June 7, 2013, (ML131640201). By letters dated June 28, 2013, (ML13183A391) and July 22, 2013, (ML13204A304) the licensee informed the NRC that the reactor fuel had been permanently removed from Units 3 and 2, respectively. The licensee submitted its PSDAR on September 23, 2014, (ML14269A033). In response to the licensees amendment request, the NRC issued the Permanently Defueled Technical Specifications on July 17, 2015, (ML15139A390) along with revised facility operating licenses to reflect the permanent cessation of operations at SONGS Units 2 and 3.
On March 11, 2016, (ML16055A522) the NRC issued two revised facility operating licenses for Units 2 and 3, in response to the licensees amendment request dated August 20, 2015, (ML15236A018). The license amendment allowed for the licensee to revise its Updated Final Safety Analysis Report (UFSAR) to reflect the significant reduction of decay heat loads in the SONGS Units 2 and 3 spent fuel pools resulting from the elapsed time since the permanent shutdown of the units in 2012. The revisions support design basis changes made by the licensee associated with implementing the cold and dark plant status described in the PSDAR.
Current work in progress included construction of cold and dark plant status modifications that include a stand-alone electrical ring bus, a new switchgear room, and approximately 70,000 feet of cabling to support electrical power needs during decommissioning. The licensee also continued to construct the SFP islanding equipment in accordance with the PSDAR and the description submitted in its license amendment request letter dated August 20, 2015, (ML15236A018).
The licensees management, safety review, and other oversight committees are being conducted and maintained in accordance with appropriate regulatory requirements as prescribed by the SONGS DQAP. The licensee is implementing its corrective action program in accordance with appropriate regulatory requirements as prescribed by the SONGS DQAP and in accordance with the applicable regulatory requirements and license conditions.
In addition, the licensees work activities, which included removal of systems from service that were no longer required to maintain the integrity of the reactor coolant pressure boundary, shutdown of the reactor, and maintain the reactor in a shutdown condition, were completed in accordance with the licensees safety review processes.
During the onsite inspection, the licensee was performing fuel examination activities and preparing for the new ISFSI pad construction. Further, the licensee continued to conduct routine operations, activities associated with dry cask storage operations, maintenance and surveillance activities, and environmental monitoring as required by the regulations and license requirements.
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sump drainage, salt water dilution, and building ventilation. Work that has been deferred or downgraded included modification of the health physics/chemistry laboratory and fire suppression system.
The inspectors conducted detailed walk-downs of the work in progress and reviewed the status of the various cold and dark plant modification projects. The inspectors noted that the licensees contractor was conducting work with an emphasis and keen focus on industrial safety. The licensee continued to implement the activities described in the PSDAR for the cold and dark plant modification strategy.
b. Radiological Surveys of Electrical Switchyard Area The licensee notified the NRC by letter dated March 3, 2015, (ML15071A018) of the proposed plan for San Diego Gas and Electric to construct a synchronous condenser in the southern portion of the switchyard. To support this effort, the licensee planned to conduct various radiological surveys within the area and to develop a cross-contamination prevention plan for the area. The licensee estimated that approximately 20,000 cubic yards of soil will be excavated and released as part of this construction project. The NRC inspectors reviewed the licensees plans for radiologically surveying the area.
The licensees contractor conducted a radiological characterization survey of the switchyard as part of the overall site characterization efforts. The characterization survey included: 1) walk-over gamma radiation scans using ambient gamma-detecting scintillation detectors; 2) static, fixed point measurements for gamma radiation using gamma-detecting scintillation detectors; 3) asphalt sampling; and 4) surface and subsurface soil sampling. These characterization surveys were conducted in September 2014 and March 2015. The radiation survey results indicated that several sediment samples from storm drain gutters contained measurable quantities of licensed material (cesium-137 and/or cobalt-60). All other sample results were indistinguishable from background levels. The results of the survey were documented in a Site Characterization Report dated June 2015.
The licensee has planned a phased approach for the final status survey of the synchronous condenser area. Phases I and II included surface soil, subsurface soil, and borehole sampling. These samples were collected in January 2015. Five composite samples were transferred to the NRC for independent analysis. The results of these samples are provided in NRC Inspection Report No. 050000361/2016008 and 05000362/2015008, dated July 10, 2015, (ML15191A223). The inspector reviewed and confirmed that all sample results for cobalt-60 and cesium-137 were less than the minimum detectable concentration limits for the measuring equipment.
The licensees contractor subsequently developed a Radiological Characterization Plan, which describes the scanning and soil sampling to be performed at various stages of the soil excavation work. The pre-excavation work included gamma scans and soil sampling consistent with Class 3 surveys, as defined in NUREG-1575, Revision 1, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM). These sampling efforts were completed in September 2015.
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and operations as appropriate. Each system is designed as Seismic Class III (California building code), Quality III-AQ (augmented quality), and non-safety related. Each system is designated as non-safety related because it does not have to perform a safety-related function. The NRC inspectors conducted a detailed review of SFP island system design, operations, and maintenance to verify compliance with license, PSDAR, and procedure requirements.
The inspectors compared the design of the SFP islands to the description provided in Attachment A of the license amendment request letter dated August 20, 2015, (ML15236A018), as supplemented by letter dated January 12, 2016, (ML16014A376).
The inspectors compared system components to the design specifications provided by the vendor. At the time of the inspection, the two systems, one for each unit, had been constructed and were in service. At a future date, each spent fuel island system will be made permanent and the existing systems and equipment removed from operation and eventually retired.
The inspectors reviewed the alarms, controls, and interlocks for the new systems. The licensee had installed alarms, controls, and interlocks in accordance with vendor instructions. At the time of the inspection, the active alarms in the control room consisted of a combination of new SFP island equipment alarms and several alarms connected to permanent plant equipment. As cold and dark plant modifications continue to be implemented, the licensee is expected to remove the permanent plant alarms from service.
The inspectors reviewed the system operating procedure, SO23-3-2.11.2, Spent Fuel Pool Cooling Island Operation, Revision 5. The operating procedure provided instructions for various modes of operation, including switch-over to the permanent SFP cooling equipment, if needed for operation. The inspectors confirmed that the operating instructions were in agreement with the as-built design of the system, and the operators were conducting operations in agreement with procedure requirements.
At the time of the inspection, the SFP island ion exchange columns were not in service.
The licensee had not installed resins in these columns; but instead, planned to use portable cleanup skids if pool water clarity becomes a problem.
In addition, the inspectors reviewed the licensees planned maintenance activities and confirmed that the licensee had implemented a maintenance program for the various system components. The maintenance instructions included routine verification of the tightness of bolts to maintain seismic qualification of certain spent fuel pool system components, which is included as a description in the license amendment request dated August 20, 2015, (ML15236A018).
The inspectors reviewed the licensees mitigating strategies for adding water to the SFPs during normal, off-normal, and emergency conditions. The licensee continues to maintain alternate sources of water from various sources, including the existing purification pumps, until the enhanced makeup water system has been placed into service.
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decommissioning activities are being implemented in accordance with the requirements of 10 CFR 50.59, 10 CFR 50.71, 10 CFR 72.48, and 10 CFR Part 50, Appendix B. In addition, the inspectors discussed the implementation and effectiveness of the design control and safety review programs with SONGS personnel.
The inspectors also reviewed the organization, composition, and controls implemented for each of the SONGS management and safety review committees to ensure that the licensee was maintaining effective oversight of decommissioning activities. The inspectors also attended several oversight committee meetings and discussed the program with licensee staff.
5.2 Observations and Findings a. Design Control and Plant Modifications The SONGS DQAP includes design control provisions to control inputs, processes, outputs, changes, interfaces, records, and organizational interfaces of the licensees designs. The design control provisions include requirements for verifying the acceptability of design activities and documents, consistent with their effects on safety for structures, systems, and components that have important-to-safety functions. The regulations under 10 CFR 50.59(c)(1) states in part, that a licensee may make changes in the facility as described in the UFSAR, make changes in the procedures as described in the UFSAR, and conduct tests or experiments not described in the UFSAR without obtaining a license amendment pursuant to 10 CFR 50.90 in certain situations.
The inspectors reviewed the licensees 10 CFR 50.59 safety evaluation program, as implemented by Procedure SO123-XV-44, 10 CFR 50.59 and 72.48 Program, Revision 17. The inspectors compared this procedure with the NRC-endorsed acceptable method for complying with the provisions of 10 CFR 50.59, which is the Nuclear Energy Institutes NEI 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, dated November 2000. The inspectors reviewed four screenings where licensee personnel had determined that a full 10 CFR 50.59 evaluation was not necessary and determined that the licensees safety evaluation program procedure and processes were adequate for complying with the provisions of 10 CFR 50.59 and 10 CFR 72.48.
The inspectors reviewed the meeting minutes of the Onsite Review Committee Meeting conducted on March 21, 2016. The inspectors compared the conduct of the meeting with the requirements specified in the SONGS UFSAR, Section 17.2.20.2, and SONGS Procedure SO123-XV-60.1, Revision 16. The inspectors determined that the procedure adequately implemented the description of the organization as provided in Section 17.2.20.2 of the UFSAR. Additionally, the inspectors determined that the committee members were properly trained, the committee was properly staffed to conduct meetings, and the committee members fulfilled the charter of the committee as specified in the procedure. The licensees 10 CFR 50.59 safety evaluation program provides effective periodic training for personnel preparing, reviewing, and approving the associated safety evaluations. In addition, the licensees program establishes an adequate process to assess training effectiveness.
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ML16216A364 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: Yes No Non-Sensitive Publicly Available NRC-002 OFFICE DNMS/FCDB DNMS/FCDB NMSS C:NMSS C:FCDB NAME RSBrowder REvans MVaaler BWatson JWhitten SIGNATURE /RA/ /RA/ /RA/ via email /RA/ via email /RA/
DATE 07/15/16 08/01/16 07/29/16 07/29/16 08/03/16
Letter to Thomas