ML062220655
| ML062220655 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/10/2006 |
| From: | Spitzberg D NRC/RGN-IV/DNMS/FCDB |
| To: | Rosenblum R Southern California Edison Co |
| References | |
| IR-06-012 | |
| Download: ML062220655 (14) | |
See also: IR 05000206/2006012
Text
August 10, 2006
Richard M. Rosenblum
Chief Nuclear Officer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
SUBJECT: NRC INSPECTION REPORT 050-00206/06-012
Dear Mr. Rosenblum:
This refers to the inspection conducted on July 17-21, 2006, at Southern California Edison
Companys (SCE) San Onofre Nuclear Generating Station (SONGS), Unit 1 facility. This
inspection was an examination of decommissioning activities conducted under your license as
they relate to safety and compliance with the Commissions rules and regulations and with the
conditions of your license. The inspection included an examination of selected procedures and
representative records, observations of activities, and interviews with personnel. The enclosed
report presents the results of that inspection. The inspection determined that you were
conducting decommissioning activities in compliance with regulatory and license requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be made available electronically for public inspection
in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible,
your response should not include any personal privacy, proprietary, or safeguards information
so that it can be made available to the Public without redaction.
Should you have any questions concerning this inspection, please contact the undersigned at
(817) 860-8191 or Mr. Emilio M. Garcia, Health Physicist, at (530) 756-3910.
Sincerely,
/RA/
D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle and Decommissioning Branch
Docket No.: 050-00206
License No.: DPR-13
Enclosure: NRC Inspection Report
No.: 050-00206/06-012
Southern California Edison Co. -2-
cc w/enclosure:
Chairman, Board of Supervisors
County of San Diego
1600 Pacific Highway, Room 335
San Diego, CA 92101
Gary L. Nolff
Power Projects/Contracts Manager
Riverside Public Utilities
2911 Adams Street
Riverside, CA 92504
Eileen M. Teichert, Esq.
Supervising Deputy City Attorney
City of Riverside
3900 Main Street
Riverside, CA 92522
Ray W. Waldo
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
David Spath, Chief
Division of Drinking Water and
Environmental Management
California Department of Health Services
P.O. Box 942732
Sacramento, CA 94234-7320
Michael R. Olson
San Onofre Liaison
San Diego Gas & Electric Company
P.O. Box 1831
San Diego, CA 92112-4150
Ed Bailey, Chief
Radiologic Health Branch
State Department of Health Services
P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414
Mayor
City of San Clemente
100 Avenida Presidio
San Clemente, CA 92672
Southern California Edison Co. -3-
James D. Boyd, Commissioner
California Energy Commission
1516 Ninth Street (MS 34)
Sacramento, CA 95814
Douglas K. Porter, Esq.
Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, CA 91770
James T. Reilly
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Daniel P. Breig
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
A. Edward Scherer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Brian Katz
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Southern California Edison Co. -4-
cc w/enclosure (via e-mail distribution):
LDWert
DBSpitzberg
HAFreeman
JCShepherd, NMSS/DWMEP/DD
CCOsterholtz, SRI
EMGarcia
RJEvans
KEGardin
FCDB File
SUNSI Review Completed: EMG ADAMS: O Yes G No Initials: EMG
O Publicly Available G Non-Publicly Available G Sensitive O Non-Sensitive
DOCUMENT NAME: s:\dnms\!fcdb\!emg2\6050206012.wpd final r:\_so1\2006
RIV:DNMS:FCDB C:FCDB
EMGarcia DBSpitzberg
/RA/ /RA/
08/10/06 08/10/06
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No: 050-00206
License No: DPR-13
Report No: 050-00206/06-012
Licensee: Southern California Edison Co.
P.O. Box 128
San Clemente, California 92674
Facility: San Onofre Nuclear Generating Station, Unit 1
Location: San Clemente, California
Dates: July 17 - 21, 2006
Inspectors: Emilio Garcia, Health Physicist
Fuel Cycle & Decommissioning Branch
Approved and
Accompanied By: D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle & Decommissioning Branch
Attachment: Supplemental Inspection Information
ADAMS Entry: IR05000206-06-012 on 07/17/2006 - 07/21/2006; Southern
California Edison Co., San Onofre Nuclear Generating Station;
Unit 1. Decommissioning Report. No VIOs.
-2-
EXECUTIVE SUMMARY
San Onofre Nuclear Generating Station, Unit 1
NRC Inspection Report 050-00206/06-012
This inspection was a routine, announced inspection of decommissioning activities being
conducted at San Onofre Nuclear Generating Station, Unit 1 facility. Areas inspected included
organization, management, and cost controls; safety reviews, design changes and
modifications; decommissioning performance and status review; and radioactive waste
treatment and environmental monitoring. The inspection determined that you were conducting
decommissioning activities in compliance with regulatory and license requirements.
Organization, Management, and Cost Controls at Permanently Shutdown Reactors
- The licensees organizational structure was consistent with the requirements of the
SONGS Unit 1 Technical Specifications. All managerial positions were staffed with
experienced individuals (Section 1.1).
- The licensees decommissioning funding status as reported in their Decommission
Funding Report was reviewed and found to meet applicable requirements. Based on
licensee projections of decommissioning costs and the amount of work completed at the
end of 2005, adequate funding would be available to complete Unit 1 decommissioning
(Section 1.2).
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
- The licensees safety review and design change program was in compliance with
10 CFR 50.59 requirements (Section 2).
Decommissioning Performance and Status Review at Permanently Shutdown Reactors
- The licensee was controlling the radiologically restricted area in accordance with
requirements. The licensee continued to make progress decommissioning the Unit 1
site (Section 3).
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
- The licensees programs for monitoring radioactive liquid and gaseous effluent releases
and environmental monitoring were in compliance with license requirements. All
required samples had been collected, no sample result exceeded applicable limits, and
no adverse trends were identified (Section 4).
-3-
Report Details
Summary of Plant Status
San Onofre Nuclear Generating Station (SONGS), Unit 1 was permanently shut down during
November 1992 and was permanently defueled by March 1993. The unit remained in
SAFSTOR until June 1999 when decommissioning was initiated. At the time of this inspection,
the licensee was conducting decommissioning activities under the DECON option as stated in
its Post Shutdown Decommissioning Activities Report dated December 15, 1998. DECON is
defined as the immediate removal and disposal of all radioactivity in excess of levels which
would permit the release of the facility for unrestricted use.
Work completed since the previous inspection included segmentation and removal of the spent
fuel pool liner and continued demolition of the concrete in containment.
1 Organization, Management, and Cost Controls at Permanently Shutdown
Reactors (36801)
1.1 Organization
a. Inspection Scope
The inspector reviewed the licensees organizational structure against the requirements
of the SONGS Unit 1 Technical Specifications, the De-fueled Safety Analysis Report
(DSAR) and the Topical Quality Assurance Manual (TQAM).
b. Observations and Findings
Section 6.2 of the Technical Specifications requires that the lines of authority,
responsibility and communications be established and defined for the highest
management levels through intermediate levels to include all organizations. The
Technical Specification also requires that a Southern California Edison Company (SCE)
Vice President shall be responsible for overall unit safety and that a SCE Vice President
shall have corporate responsibility for decommissioning activities.
The July 2006, amendment to the DSAR designated the Senior Vice President as the
Chief Nuclear Officer and to whom all levels of the organization report. Previously, this
position was designated as the Executive Vice-President. The Senior Vice-President
reports to the SCE Chief Executive Officer. The Vice-President Nuclear Generation had
ultimate responsibility for the safe operation of the three units. The Vice-President of
Engineering and Technical Services had responsibility for the decommissioning of
Unit 1. The DSAR further defined the lines of authority, responsibility and
communications through the intermediate levels of all onsite organizations. This
organization was consistent with that described in Chapter 1-B of the Topical Quality
Assurance Manual, with the exception that the title of Executive Vice-President had not
yet been revised to Senior Vice-President. The licensee maintained an updated
Organization Chart to reflect the individuals assigned to each position.
-4-
The incumbents to the positions of Senior Vice-President, Vice-President Nuclear
Generation, Vice-President of Engineering and Technical Services, Station Manager
and Manager, Unit 1 Decommissioning had been appointed to their positions since
December 2004, but all had many years of experience in the nuclear field and of service
with the licensee.
c. Conclusion
The licensees organizational structure was consistent with the requirements of the
SONGS Unit 1 Technical Specifications. All managerial positions were staffed with
experienced individuals.
1.2 Cost Controls
a. Inspection Scope
The inspector reviewed the licensees implementation of the requirements of
10 CFR 50.75(f)(1) regarding status of decommissioning funding.
b. Observations and Findings
10 CFR 50.75(f)(1) requires each power reactor licensee to submit a report on a 2-year
basis of (1) the amount of decommissioning funds estimated to be required for
decommissioning; (2) the amount accumulated to the end of the preceding calendar
year; (3) a schedule of annual amounts remaining to be collected; (4) the assumptions
used regarding the rates of escalation in decommissioning cost; (5) the rates of
earnings on decommissioning funds; (6) rates of other factors used in funding
projections; (7) any contracts upon which the licensee is relying pursuant to
10 CFR 50.75(e)(1)(v); (8) any modifications occurring to a licensees current method of
providing financial assurance; and (9) any material changes to trust agreements. This
regulation requires the biennial report to be submitted by March 31 of the reporting year.
The report covering the decommissioning fund status through calendar year 2005 was
submitted to the NRC on March 13, 2006. This timely report included information on the
nine items required in 10 CFR 50.75(f)(1).
c. Conclusion
The licensees decommissioning funding status as reported in their Decommission
Funding Report was reviewed and found to contain all information required by 10 CFR
50.75. Based on licensee projections of decommissioning costs and the amount of work
completed at the end of 2005, adequate funding would be available to complete Unit 1
decommissioning.
2 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown
Reactors (37801)
-5-
2.1 Inspection Scope
The purpose of this portion of the inspection was to ascertain whether the licensee's
training program provides effective periodic training for personnel preparing, reviewing,
and approving safety evaluations.
2.2 Observations and Findings
Regulation 10 CFR 50.59 addresses the change control process, a process used by the
licensee to determine if a proposed change to the facility, procedures, tests, or
experiments is subject to a license amendment and NRC approval. The process is
implemented through site procedure SO123-XV-44, "10 CFR 50.59 and 72.48
Program." This procedure provided instructions for both initial screening and
subsequent full evaluation, if necessary, of facility or procedure changes to confirm if the
licensee can implement these changes without NRC approval. The program was a
common program for the two operating units and the decommissioning unit. The initial
screens and full evaluations are documented through the computerized Action Request
System. This computerized system checks to verify that the individual preparing,
reviewing and approving safety screens and full evaluations were current in their
training.
During the period of July 1, 2005 to July 17, 2006, no 10 CFR 50.59 safety evaluations
were conducted for Unit 1 activities and 35 safety screens were created or closed. The
inspector reviewed the training records and determined that all preparers and reviewers
were current with their training.
The inspector reviewed On-site Review Committee meeting minutes for the period of
June 1, 2005 to June 21, 2006. This committee had a standing agenda item to review
10 CFR 50.59 safety evaluations. The minutes indicated that no Unit 1 10 CFR 50.59
safety evaluations had been performed during this period. The minutes of the
February 15, 2006, meeting note that the Director, Unit 1 Decommissioning was no
longer a member of the Committee. This change was favored by the Director, Unit 1
Decommissioning and in view of the status of Unit 1 was acceptable.
2.3 Conclusions
The licensees safety review and design change program was in compliance with
10 CFR 50.59 requirements.
3 Decommissioning Performance and Status Review at Permanently Shutdown
Reactors (71801)
3.1 Inspection Scope
The inspectors evaluated whether the licensee and its contracted workforce were
conducting decommissioning activities in accordance with license and regulatory
requirements.
-6-
3.2 Observations and Findings
a. Site Tours/Control of Decommissioning Activities
The inspector conducted tours of the Unit 1 facility to observe radiological area postings
and boundaries. Access to the restricted and contaminated areas was controlled by
radiation caution signs, barricades, boundary lines, locked doors, and locked gates.
Radiological boundaries were well defined and postings were up-to-date in all areas.
The inspector conducted independent radiological surveys in the radiologically restricted
area using a Ludlum Model 2401-EC survey meter (NRC No. 21173G, calibration due
date 09/23/06). No abnormal radiological survey results were observed and all ambient
gamma exposure rate measurements were in agreement with posted radiation levels.
During this inspection, the licensee completed solidifying previously collected
radiologically contaminated water. The licensee intended to ship the resulting solid to
an offsite disposal site.
Removal of the steel spent fuel pool liner had been completed. The steel spent fuel
pool liner anchors imbedded in the concrete were being removed during this inspection.
Contaminated concrete surface in the spent fuel building was being scabbled to reduce
contamination to levels acceptable for open-air demolition.
Work was continuing with the demolition and removal of the concrete in containment. A
mechanical excavator had inadvertently pierced the steel containment resulting in flow
of water into the containment. The licensee concluded that the containment sphere
could become buoyant if it was not attached to the concrete base as originally
envisioned. The licensee had developed a plan to anchor the steel sphere to the
concrete base and to de-water the ground around the base to assure that the steel
sphere did not become buoyant. The location of some of the de-watering wells required
prior removal of the turbine building North extension. The turbine building North
extension was needed for the demolition of the upper portions of the spent fuel building.
The licensee had completed construction of the new yard sump and was preparing to
isolate the original intake and outfall canals. The eventual goal was to have these
structures released from the license. The licensee stated that they would keep NRC
informed of their schedule for sampling these structures.
The licensee had removed more than 46 percent (by weight) of the waste to be
removed.
3.3 Conclusions
The licensee was controlling the radiologically restricted area in accordance with
regulatory requirements. The licensee continued to make progress in decommissioning
of the Unit 1 site.
4 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)
-7-
4.1 Inspection Scope
The inspector reviewed the licensees program to control, monitor, and quantify releases
of radioactive materials to the environment in liquid, gaseous, and particulate forms.
4.2 Observations and Findings
a. Effluent Monitoring
Section D6.8.4.a of the Permanently Defueled Technical Specifications states that a
radioactive effluent control program shall be established, implemented, and maintained.
The methodology used to monitor, sample, and analyze the liquid and gaseous effluents
is provided in the Offsite Dose Calculation Manual (ODCM). The inspector compared
the program requirements specified in the ODCM to the sample results as documented
in the licensees 2005 Annual Radioactive Effluent Release Report (ARERR) dated April
24, 2006. This report was submitted on time and the licensee collected all samples
required by the ODCM. No sample result exceeded the applicable reporting level.
The report states that doses to an individual due to liquid effluents, airborne releases
and direct radiation were all a fraction of a millirem and well below the applicable limits.
The report notes that the ODCM was revised on February 25, 2005, with Revision 23.
This revision incorporated 1) removal of all the "notes" and applicable sections regarding
the completion of fuel transfer to the Independent Spent Fuel Storage Installation
(ISFSI), 2) addition of notes supporting the planned demolition of the liquid radwaste
treatment system, 3) updates related to the 2003-2004 Land Use Census, 4) corrected
dilution flow rate values, and 5) a minor change to a radiological environmental
monitoring program (REMP) sampling location. The report also notes that Liquid
Radwaste Treatment System (LRTS) was permanently removed from service on May
13, 2005. The sump pumps, piping and radiation monitoring system skid were removed
to support the demolition of the radwaste building.
The 2005 annual radioactive effluent release report also included solid waste shipment
information. During 2005, the licensee shipped solid wastes to disposal sites in Utah
and South Carolina, and to a volume reduction service in Utah. The licensee sent 85
shipments by rail and 153 shipments by truck. In addition, two shipments went to a
volume reduction contractor. The contractor subsequently shipped the compacted
wastes to the disposal site in Utah.
b. Environmental Monitoring
Section D6.8.4.b of the Permanently Defueled Technical Specifications states that a
radiological environmental monitoring program shall be established, implemented and
maintained. Program requirements are contained in the ODCM. The inspector
compared the ODCM requirements with the information provided in the licensees 2005
radiological environmental operating report dated April 24, 2006. The report Annual
Radiological Environmental Operating Report (AREOR) was applicable to all three
Units and ISFSI). This report was submitted on time and all ODCM required samples
had been obtained. No sample result exceeded the applicable regulatory limit.
-8-
Ambient radiation levels were measured at least 30 locations with calcium sulfate
(CaSO4) thermoluminescent dosimeters (TLDs). The environmental dosimeters were
exchanged quarterly. During 2005, the average routine indicator location dose was
17.19 millirem with a range of 10.13 to 29.32 millirem. The average control location
dose was 16.12 millirem with a range of 12.96 to 20.05 millirem. The report concluded
that statistically, the control and indicator doses were equivalent. The results suggests
that plant operation had a negligible effect on the ambient dose rates.
Air particulate samples were collected on a weekly basis from eight indicator locations
and from one control location. The samples were analyzed for gross beta activity, I-131,
and composited quarterly for gamma isotopic analysis. Per the requirements of ODCM,
the licensee evaluated the gross beta activity of the indicators to the control locations.
The indicator locations maximum gross beta activity in air in 2005 was 0.0791
picocuries per cubic meter and the 2004 control location average was 0.0245 picocuries
per cubic meter. No indicator location value exceeded ten times the annual average
gross beta activity of the control location data from the previous year. All iodine-131
sample results were below the lower limit of detection. Quarterly composite gamma
spectral analysis analyses identified only naturally occurring beryllium-7 (Be-7).
The licensee collected monthly ocean water samples from locations in the vicinity of
each station discharge and from the control location. The samples were analyzed for
naturally-occurring and licensee-related radionuclides. Quarterly composite ocean
water samples were analyzed for tritium. Naturally occurring potassium-40 (K-40) was
detected in all ocean water samples obtained in 2005. No licensee-related
radionuclides were detected in ocean water samples during 2005.
Drinking water samples were collected on a monthly basis from one indicator location
and from a control location. Samples were analyzed for tritium, gross beta, and 26
naturally-occurring and licensee-related radionuclides. No station-related radionuclides
were detected in drinking water during 2005.
Fish, crustacea and mollusks, were collected on a semi-annual basis at the SONGS
Unit I outfall and from a control location. The flesh portion of each sample type was
analyzed for 26 station-related and naturally-occurring radionuclides. Naturally-
occurring K-40 was detected in most marine samples collected during 2005. No
plant-related isotopes were reported above the minimum detectable concentration
(MDC).
The licensee conducted an internal quality assurance audit of the ODCM program
during August-September 2004, which was reviewed in a previous inspection. The next
audit of this area was scheduled for August 2006.
In summary, the licensee concluded that the site had a negligible radiological
environmental impact during 2005. The inspector found that the sample results
supported this conclusion. Further, no adverse trends were identified.
-9-
4.3 Conclusions
The licensees programs for monitoring radioactive liquid and gaseous effluent releases
and environmental monitoring were in compliance with license requirements. All
required samples had been collected, no sample result exceeded applicable limits, and
no adverse trends were identified.
5 Exit Meeting Summary
The inspector presented the preliminary inspection results to members of licensee
management at the exit meeting on July 21, 2006. The licensee did not identify as
proprietary any information provided to, or reviewed by, the inspector.
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee
D. Brieg, Station Manager
S. Enright, Unit 1 Health Physics Manager
N. Hansen, Technical Specialist, Environmental
M. Kelly, Engineer, Nuclear Regulatory Affairs
M. Kirby, Operations Supervisor Unit 1
M. Mason, Unit 1 Health Physics Supervisor
J. Morales, Manager, Decommissioning
J. Scott, Technical Specialist, Nuclear Regulatory Affairs
INSPECTION PROCEDURES USED
IP 36801 Organization, Management and Cost Controls
IP 37801 Safety Reviews, Design Changes, and Modifications
IP 71801 Decommissioning Performance and Status Review
IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
ITEMS OPENED AND CLOSED
Opened
None
Closed
None
Discussed
None
LIST OF ACRONYMS
AREOR Annual Radiological Environmental Operating Report
ARERR Annual Radioactive Effluent Release Report
DSAR De-fueled Safety Analysis Report
ISFSI Independent Spent Fuel Storage Installation
ODCM Offsite Dose Calculation Manual
K-40 Potassium-40
LRTS Liquid Radwaste Treatment System
MDC Minimum Detectable Concentration
REMP Radiological Environmental Monitoring Program
SCE Southern California Edison Company
TLDs Thermoluminescent Dosimeters
TQAM Topical Quality Assurance Manual