ML16127A580
| ML16127A580 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/05/2016 |
| From: | Whitten J Division of Nuclear Materials Safety IV |
| To: | Thomas J. Palmisano Southern California Edison Co |
| R. Browder | |
| References | |
| IR 2016001 | |
| Download: ML16127A580 (34) | |
See also: IR 05000361/2016001
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
May 5, 2016
Mr. Thomas J. Palmisano
Vice President and Chief Nuclear Officer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION
REPORTS 05000361/2016001; 05000362/2016001 AND 07200041/2016001
Dear Mr. Palmisano:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspections conducted on
March 7-10, 2016, and March 21-24, 2016, at the San Onofre Nuclear Generating Station,
Units 2 and 3, and the Independent Spent Fuel Storage Installation. The NRC inspectors
discussed the results of these inspections with you and other members of your staff at the final
exit meetings on March 10, 2016, and March 24, 2016. The inspection results are documented
in the enclosure to this inspection report.
The NRC inspections examined 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. Within these areas, the inspections consisted of selected examination of procedures
and representative records, observations of activities, and interviews with personnel. No
violations were identified and no response to this letter is required.
The inspection conducted the week of March 7, 2016, reviewed your dry fuel storage operations
and compliance with the Transnuclear Certificate of Compliance No. 1029, Amendment 1,
Updated Final Safety Analysis Report, Revision 3, and the regulations under Title 10 of the
Code of Federal Regulations 9a0 CFR) Part 20 and Part 72. Within these areas, the inspection
included a review of radiation safety, cask thermal monitoring, quality assurance, the corrective
action program, the safety evaluation program, and changes made to your ISFSI program since
the last routine ISFSI inspection that was conducted by the NRC.
In addition, the inspection conducted the week of March 21, 2016, reviewed the
decommissioning activities of Units 2 and 3 involving the transition to cold and dark plant
status, spent fuel safety, radioactive effluents and environmental monitoring, the quality
assurance program and design change process. The decommissioning activities were
reviewed for compliance with your Permanent Defueled Technical Specifications, Offsite
Dose Calculation Manual, Post-Shutdown Decommissioning Activities Report and the
regulations under 10 CFR Part 20 and Part 50.
T. Palmisano -2-
In accordance with 10 CFR 2.390, Rules of Practice and Procedure, a copy of this letter will be
available electronically for public inspection in the NRCs Public Document Room or from the
Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access
and Management System (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
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
Enclosure:
Inspection Report 05000361/2016001;
05000362/2016001; 07200041/2016001
w/Attachment: Supplemental Information
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos. 050-00361; 050-00362; 072-00041
Report Nos. 05000361/2016001; 05000362/2016001; 07200041/2016001
Licensee: Southern California Edison Company
Facility: San Onofre Nuclear Generating Station, Units 2 and 3; and
Independent Spent Fuel Storage Installation
Location: 5000 South Pacific Coast Highway, San Clemente, California
Dates: March 7 through March 10, 2016
March 21 through March 24, 2016
Inspectors: Rachel S. Browder, C.H.P., Senior Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Robert J. Evans, Ph.D., C.H.P., Senior Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Eric Simpson, Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Marlayna Vaaler, Project Manager
Reactor Decommissioning Branch
Division of Decommissioning, Uranium Recovery and Waste Programs
Office of Nuclear Material Safety and Safeguards
Approved By: Jack E. Whitten, Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
-1- Enclosure
EXECUTIVE SUMMARY
NRC Inspection Reports 05000361/2016001; 05000362/2016001 and 07200041/2016001
Southern California Edison
These U.S. Nuclear Regulatory Commission (NRC) inspections were routine, announced
inspections of decommissioning activities and dry fuel storage operations being conducted at
the San Onofre Nuclear Generating Station (SONGS). In summary, the licensee was
conducting these activities in accordance with site procedures, license requirements, and
applicable NRC regulations.
Decommissioning Performance
- The licensee continued to implement the cold and dark modifications in accordance with
Post-Shutdown Decommissioning Activities Report (PSDAR) requirements. The
licensee continues to install the spent fuel pool (SFP) makeup systems, and the licensee
continued to implement the mitigation strategies as required by the two licenses. The
licensee continued to plan for the construction of the synchronous condenser. The
licensee established survey plans and implementing procedures based on NRC-
accepted guidance for final status surveys. Finally, the inspectors conducted site tours
within the radiologically restricted areas and concluded that the licensee was maintaining
the areas in accordance with radiation protection procedures and regulatory
requirements. (Section 1.2)
Spent Fuel Pool Safety
- The licensee was operating and maintaining the SFP island systems in accordance with
PSDAR, license commitment, and procedure requirements. The licensee also installed,
operated, and maintained the SFP island equipment in accordance with the PSDAR,
vendor information, and approved procedures. (Section 2.2)
Radioactive Waste Treatment, Effluent, and Environmental Monitoring
- The licensees effluent monitoring and environmental monitoring programs were being
conducted in accordance with appropriate regulatory requirements as prescribed by the
SONGS Offsite Dose Calculation Manual (ODCM). (Section 3.2)
Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors
- The licensee is implementing its corrective action program in accordance with
appropriate regulatory requirements as prescribed by the SONGS Decommissioning
Quality Assurance Program (DQAP.) Based on the sample of documents reviewed and
activities observed, the inspectors determined that the licensee is successfully
implementing its policies and procedures associated with the corrective action program
in accordance with the applicable regulatory requirements, license conditions, and
DQAP procedures. (Section 4.2)
-2-
- The licensees auditing and decommissioning safety review programs are being
conducted and maintained in accordance with the appropriate regulatory requirements
as prescribed by the SONGS DQAP. The licensee has established audit, review, and
oversight programs to ensure that activities are being conducted in accordance with the
applicable regulatory requirements, license conditions, and DQAP procedures. These
programs function in a timely, independent, and appropriate manner. (Section 4.2)
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
- The licensees safety review processes, procedures, and training programs are being
conducted and maintained in accordance with the appropriate regulatory requirements
as prescribed by the SONGS DQAP. The licensee has established Title 10 of the
Code of Federal Regulations (10 CFR) 50.59 and 10 CFR 72.48 programs to ensure
that activities are being conducted in accordance with the applicable regulatory
requirements, license conditions, and DQAP procedures. 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. (Section 5.2)
- 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 has established additional oversight and
controls for contractor programs to ensure that activities are being conducted in
accordance with the applicable regulatory requirements, license conditions, and DQAP
procedures. (Section 5.2)
Operation of an Independent Spent Fuel Storage Installation
- The inspectors observed that the licensee had met the licensing requirements for the
documents and activities reviewed associated with the dry cask storage activities at
SONGS. (Section 6.2)
Review of 10 CFR 72.212(b) Evaluations
- The licensee was maintaining the 10 CFR 72.212 Evaluation Report current as required.
Two changes to the 10 CFR 72.212 report had been made since the last NRC
Independent Spent Fuel Storage Installation (ISFSI) inspection in 2014. (Section 7.2)
Review of 10 CFR 72.48 Evaluations
- All required screens and safety evaluations had been performed in accordance with
procedures and 10 CFR 72.48 requirements. All of the 10 CFR 72.48 screens that were
reviewed were determined to have been adequately evaluated by the licensee.
(Section 8.2)
-3-
Follow-up of Events
- Licensee Event Report 05000361/2015-002-00, Spent Fuel Pool Temperature Drifted
Below Updated Final Safety Analysis Report Value was reviewed and closed.
(Section 9.1)
-4-
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 with the
commitments made in its license amendment request 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.
-5-
1. Decommissioning Performance (71801)
1.1 Inspection Scope
The inspectors evaluated whether the licensee and its contracted workforce were
conducting decommissioning activities in accordance with license and regulatory
requirements.
1.2 Observations and Findings
a. Review of Cold and Dark Plant Modifications
The PSDAR,Section II, provides an overview of the planned decommissioning activities.
These activities include site modifications as necessary to support future
decommissioning and decontamination efforts. One such modification mentioned in
Section II.A of the PSDAR is the planning, design, and implementation of cold and
dark. The licensee plans to have all cold and dark plant modifications in place by
mid-2016. The inspectors reviewed the status of the licensees efforts in implementing
the cold and dark plant modifications.
As of March 2016, the priority work included final installation of the 12-kilovolt, non-
safety and seismic Category III, electrical ring bus and associated equipment that will
facilitate decommissioning of various plant systems. The ring bus work included
installation of electrical cables, panels, raceways, and cabinets. The 12-kilovolt line at
the time of the inspection had been installed and temporarily energized. The licensee
plans to connect two backup diesel generators (500-kilowatt and 1500-kilowatt) to the
ring bus. These two diesel generators will provide power to critical cold and dark
equipment and electrical panels during loss of power events. In addition, the licensees
contractor was wiring the electrical panels in the 37-foot elevation of the radwaste
building. The electrical panels will convert the 12-kilovolt incoming power to
480/120-volt power for distribution into the plant. The new electrical distribution system
is identified by orange-colored cabling that easily stands apart from the permanent plant
electrical distribution systems, which will be decommissioned.
In addition to the electrical distribution work, the licensee was installing an enhanced
SFP makeup system for each unit. The systems are classified as augmented quality
and seismic Category I. The purpose of the SFP makeup system is to protect spent fuel
cladding by maintaining water level in the spent fuel pool. The system will provide
demineralized makeup water from the existing primary makeup storage tank to the
respective SFP. The planned work consisted of reusing two existing plant pumps,
installing a new high-capacity makeup pump, and installing the associated piping,
valves, and instrumentation. At the time of the inspection, the licensee continued to
keep the permanent plant makeup equipment in service until the new system had been
constructed and tested. The licensee had developed, but had not issued, operating
procedures for the new equipment.
Other cold and dark plant modification work in progress included the installation or
modification of the command center, security power, telecommunications, fire detection,
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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 commitments provided 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.
-7-
The Radiological Characterization Plan also provides instructions for sampling during
excavation and after completion of excavation. During excavation, the sampling will
consist primarily of composite soil sampling, to ensure that the excavated soil does not
contain licensed material in quantities distinguishable from background levels. Backfill, if
used, will also be composite sampled to ensure that it does not contain radioactive
material. Finally, the final grade for the synchronous condenser will be gamma scanned
using gamma-detecting scintillation detectors and soil sampled for use as final status
survey data. The licensee stated that after the area has been released for construction
of the synchronous condenser they plan to implement a cross-contamination prevention
plan in order to control the area
The licensee currently plans to free-release some or all of the excavated soil. The soil
will be released in accordance with the licensees approved material release work plan
provided in Radiation Protection Procedure SO123-VII-20.9.3, Revision 12, Surveys for
Release of Liquids, Sludges, Slurries, and Sands. The acceptance criteria for release
will be no detectable activity. The inspectors noted that none of the soil samples
collected in the vicinity of the proposed synchronous condenser contained any
detectable quantities of licensed radiological material, indicating that the soil could be
unconditionally released from the switchyard.
The licensee committed in Section II of the PSDAR to conduct final site surveys in
accordance with the MARSSIM guidance in NUREG-1575. Based on the licensees
characterization survey that was performed, as well as its proposed survey plan and
procedures for the synchronous condenser work, the inspectors concluded that the
licensee has developed and implemented a radiological survey program for the
synchronous condenser activity using the guidance provided in MARSSIM.
c. Radiological Response Plan for ISFSI Pad Excavation
The licensee plans to construct a new ISFSI pad in the North Industrial Area (NIA). This
area includes the footprint of the former SONGS Unit 1 plant that was decommissioned in
1999-2009. The ISFSI pad construction work will require excavation of soil up to 12 feet
below the ground surface. Since the soil may contain low levels of radioactivity remaining
from Unit 1 decommissioning, the licensee plans to conduct soil sampling and gamma
radiation scans as part of the excavation process.
The licensee developed procedures to implement radiological controls in the event any
radioactivity is encountered during the soil excavation work. The procedures provide
instructions for worker protection under four scenarios: 1) no licensed material identified;
2) radioactive material identified by soil sampling but not gamma scans; 3) radioactive
material identified by both soil sampling and gamma scans; and 4) hydrogen-3 (tritium) is
identified in groundwater, if shallow groundwater is encountered during excavation work.
The licensee plans to reuse the soil, if the soil contains less than 10-percent of the
proposed, derived concentration guideline levels; otherwise, the licensee will most likely
dispose of the soil. The NRC has not approved a derived concentration guideline level for
this site; thus, any application of a derived concentration guideline level will be conducted
at risk by the licensee.
-8-
The licensee developed basic radiological controls, including training of workers, surveys
of the work area, and posting of the work area, which are independent of the various
worker protection controls developed for each scenario. The licensee also plans to
conduct limited air particulate sampling during excavation activities. Air particulate
sampling may include lapel or portable area air samplers. The inspectors determined
that the licensees proposed controls are commensurate with the potential radiological
conditions in the area and addresses the potential risks for each scenario that may be
encountered.
d. Site Tours
During site tours within the radiologically restricted areas, the inspectors conducted
independent gamma radiation measurements using a Ludlum Model 2401-EC2 survey
meter (NRC No. 35484G, calibration due date of March 13, 2016.) The inspectors
also observed the status of boundaries, postings, and labeling to ensure compliance
with regulatory and procedural requirements. The inspectors survey measurements
were comparable to the survey results as presented on area maps created by the
licensees health physics staff. In the areas toured, the licensee implemented radiation
protection controls, including postings and labeling, that were in compliance with
regulatory and procedure requirements.
1.3 Conclusion
The licensee continued to implement the cold and dark plant modifications in
accordance with PSDAR requirements. The licensee continued to install the SFP
makeup systems and implement the mitigation strategies as required by the two
licenses. The licensee continued to plan for the construction of the synchronous
condenser. The licensee established survey plans and implementing procedures based
on NRC-accepted guidance for final status surveys. Finally, the inspectors conducted
site tours within the radiologically restricted areas and concluded that the licensee was
maintaining the areas in accordance with radiation protection procedures and regulatory
requirements.
2. Spent Fuel Pool Safety (60801)
2.1 Inspection Scope
The inspectors conducted a review of the Units 2 and 3 SFP island equipment to ensure
that the licensee had constructed and implemented the systems in accordance with
license, technical specifications, and procedural requirements.
2.2 Observations and Findings
A description of planned decommissioning activities is provided in Section II of the
PSDAR. To support these decommissioning efforts, the licensee committed to design
and install SFP islands for each of the two units. These systems are necessary to
support spent fuel storage until the fuel has been transferred to the onsite ISFSI. In the
PSDAR, the licensee also committed to perform equipment maintenance, inspection,
-9-
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 commitments made in the
licensees system description provided in Attachment A to its letter dated
August 20, 2015, (ML15236A018), as revised 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 reviews of the
seismic restraints, a commitment that was made in the licensees August 20, 2015,
(ML15236A018) letter to the NRC.
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.
- 10 -
2.3 Conclusion
The licensee was operating and maintaining the SFP island systems in accordance with
PSDAR, license commitment, and procedure requirements. The licensee also installed,
operated, and maintained the SFP island equipment in accordance with the PSDAR,
vendor information, and approved procedures.
3. Radioactive Waste Treatment, Effluent, and Environmental Monitoring (84750)
3.1 Inspection Scope
The inspectors reviewed the licensees radioactive effluent and environmental
monitoring programs to verify that the programs are implemented consistent with the
licensees technical specifications and ODCM requirements. In addition, the inspectors
verified that the radiological environmental monitoring program monitored non-effluent
exposure pathways, and validated that doses to members of the public are within the
dose limits provided in 10 CFR Part 20; 10 CFR Part 50, Appendix I; and
40 CFR Part 190, as applicable.
3.2 Observations and Findings
Technical Specifications, Section 5.5.2, for the two licenses require the licensee to
establish, implement, and maintain the ODCM. The ODCM provides detailed guidance
for conducting the SONGS Radiological Environmental Monitoring Program (REMP) and
the methodology and parameters used in the calculation of offsite doses resulting from
gaseous and liquid effluents. The ODCM also provides the gaseous and liquid
monitoring alarms and trip set points for the respective monitors. The NRC regulations
specific for monitoring, control, treatment, and reporting of radioactive effluents released
from the site apply regardless of the operating status of a nuclear power plant; thus, they
continue to apply in decommissioning status. The inspectors performed tours of the
facility, specifically focusing on the radioactive effluent systems, including the NIA, which
is the footprint for Unit 1; turbine plant sumps; Unit 2 outfall; containment monitors; plant
vent stack monitors; and the chemistry laboratories. The inspectors reviewed operations
logs from August 1, 2015, through March 3, 2016, regarding the effluent monitors.
a. ODCM Changes
On July 17, 2015, the NRC approved the Permanent Defueled Technical Specifications,
which removed a number of systems from the technical specifications, including:
- Containment Systems
- Certain Plant Systems
- Refueling Operations
- Gas Storage Tanks
- Explosive Gas Monitoring Instrumentation
- 11 -
Based on the NRCs approved changes to the Permanent Defueled Technical
Specifications, the licensee subsequently retired these plant systems from service using
guidance provided in procedure SO123-XXIV-10.1, Engineering Design Control
Process - NECPs. Two of the plant systems, the gaseous radwaste system and coolant
radwaste system, required 10 CFR 50.59 evaluations be completed by engineering to
permanently retire the systems. The licensee performed 12 Effluent Program/ODCM
Change screenings, in which the licensee determined that 6 of the screenings required an
evaluation.
Permanent Defueled Technical Specification 5.5.2.1.1 allows the licensee to make
changes to its ODCM, provided there is sufficient information to support the change
together with the appropriate analyses or evaluations to justify the change, and the
levels of radioactive effluent control as required by the NRC regulations are not
adversely impacted, and the change has been reviewed by the licensee and found
acceptable. After performing the appropriate screenings and evaluations, the licensee
made changes to its ODCM program that included: 1) removing equipment, monitors,
and devices from the program; 2) changing sample collection points; and 3) relocating a
garden. These changes were performed in order to accurately reflect the current
conditions at the site for monitoring, analysis, and reporting of radioactive effluents
released from the site.
The licensee processed the Effluent Program/ODCM Changes under its nuclear
notification (NN) system and assigned each one a respective tracking number. The
inspectors reviewed the 12 screenings and 6 evaluations. In particular, the following is a
list to highlight some of the changes that were performed, and which have been updated
to the ODCM, Volume 9, dated November 9, 2015.
- Evaluation NN: 203063159-002, Removal South Yard Facility Decontamination
Area Exhaust Gaseous Particulate and Iodine Sampler
- Evaluation NN: 203063159-005, Removal of the Steam Generator Blowdown
System Liquid Radiation Monitors 2(3)RE6753 and 2(3)RE6759
- Evaluation NN: 203063159-010, Removal of the Unit 2 and 3 Containment
Purge System Gaseous Radiation Monitors 2(3)RE7828
- Screening NN: 203063159-084, Site Boundary Sample Garden Relocation
- Screening NN: 203063159-012, Fuel Handling Building tritium sample location
change
- Screening NN: 203063159-008, Removal of Pressurized Ion Chambers (PICs)
from the ODCM
The licensee documented the screenings sufficiently and the inspectors did not identify
any changes that were incorrectly screened or required further evaluation. For the
evaluations that were performed regarding the permanently retired equipment, monitors,
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and devices, the licensee provided historical effluent release data from the respective
release points, as applicable, to justify there was no impact to the monitoring, control,
treatment, and reporting of radioactive effluents released from the site. Since the
equipment was drained and retired from service, there are no ODCM sampling and
analysis requirements. The licensee stated that operations staff hung clearances on the
respective plant equipment to ensure the inputs are isolated. The inspectors reviewed
the data and concluded that the licensee provided adequate analyses and justifications
to support the Effluent Program/ODCM Change evaluations that were approved.
b. Liquid Effluents
Based on the number of plant systems that have been drained and permanently retired
from service, and since the licensee has shipped all resins offsite, the licensee does not
process any radioactive liquid wastes. The liquid wastes that remain onsite and any
liquids captured through the miscellaneous liquid waste system are stored in tanks at the
facility. The tanks include the liquid radwaste primary and secondary tanks, the
chemical wastes tanks, miscellaneous waste tanks, and the condensate monitor tanks.
Operations tracks the amount of liquids being held in the tanks. The tanks provide
plenty of volume for the licensee to store liquid wastes, especially since there is no
significant generation of additional liquid wastes. The licensee plans to store its liquid
wastes until the decommissioning general contract is awarded and stated that the
contactor is expected to develop its plan to process the liquid wastes.
The only continuous release points for Units 2 and 3 liquid effluents are through the two
turbine plant sumps, which are then routed to the Unit 2 outfall. These sumps collect all
normal equipment and floor drainage from the turbine plant area. The east sump also
collects drainage from the auxiliary building sump. Any rain water that accumulates in
the full flow condensate polisher demineralizer or blowdown processing system is routed
to the Unit 2 turbine plant sumps. The licensee no longer utilizes the Unit 3 outfall. The
isolation valves to the Unit 3 outfall are locked in the closed position and removed from
service. The licensee stated it was installing four new salt water dilution pumps at the
Unit 2 outfall, and installing new piping between Unit 3 and Unit 2 outfall. The new
dilution pumps will be used by the decommissioning general contractor to process liquid
wastes, which are currently stored in the tanks onsite.
Rainfall runoff generally collects in the NIA yard. The NIA yard drain sump is credited as
a liquid radioactive effluent release point and equipped with a continuous radiation
monitor (2/3-2101). The licensee performs a weekly sample of the NIA yard sump if the
pump is running or collects a composite as necessary. The NIA yard sump is a
continuous release pathway to the Unit 2 outfall.
The licensee updated its administrative factors for ODCM liquid set-point values on
December 10, 2015. The data is used in the dose projection calculation for liquid
effluents and reflects the predominant methods of liquid effluent pathways. The
administrative factors are 0.35 for the NIA yard, 0.40 for radwaste discharge, and 0.10
for each Unit 2 and Unit 3 turbine plant sumps. There are no other discharge pathways
available. At the time of the inspection, the licensee was using salt water cooling pumps
to support SFP cooling system operations. The salt water cooling pumps do not
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produce enough dilution flow and the licensee indicated that they would not perform any
liquid releases using the salt water cooling pumps.
c. Gaseous Effluents
During the inspection, the licensee informed the inspectors that the primary gaseous
effluent pathway is through the plant vent stack. Another gaseous release point at the
site is the South Yard Facility work area exhaust. Based on Effluent Program/ODCM
Change evaluation NN 203063159-010, noted above, the Units 2 and 3 containment
purge system gaseous radiation monitors 2(3)RE7828 and associated equipment were
removed from the ODCM. The Units 2 and 3 main purge isolation valves are failed
closed and de-energized. The licensee stated that since permanent shutdown of both
units, the radioactive release permits for airborne contamination in the Units 2 and 3
containments have identified tritium, with the exception that Unit 3 did not have any
purges in 2014. Noble gases have not been detected in any containment purge samples
since shutdown, and particulates were detected in only one sample for Unit 2 in 2013.
The particulates were cobalt-60 and manganese-54 at very low levels of maximum
permissible concentration of < 1E-10 microcuries/cubic-centimeter. The licensees
evaluation documented that if a containment purge is needed, then operations can
realign the units plant vent stack to the containment purge stack and plant vent stack
monitors 2(3)RE7865 would be used to monitor the release.
The licensee updated its administrative factors for ODCM gaseous set point values on
December 22, 2015. The data is used in the dose projection calculation for gaseous
effluents and reflects the predominant methods of gaseous effluent pathways. The
administrative factors are 0.38 for plant vent stack monitors 2/3RT-7808 and 2RT-7865.
When monitor 2RT-7865 is aligned to containment, the administrative factor is
typically 0.19.
d. ODCM Program
Section 5.3.1 of the ODCM specifies that analyses shall be performed on radioactive
materials supplied as part of an Interlaboratory Comparison Program that complies with
Regulatory Guide 4.15, Revision 1, Quality Assurance for Radiological Monitoring
Programs. The licensee used GEL Laboratories as the contracted vendor to perform
environmental analysis and used Environmental Dosimeter Company as the contracted
vendor to process and analyze the REMP thermoluminescent dosimeters (TLDs). The
inspectors reviewed the vendors quality assurance audits and the nuclear oversight
vendor audits. Following are the specific reports reviewed:
- Environmental Dosimeter Company, Annual Quality Assurance Status Report,
January - December 2015
- GEL Laboratories LLC, 2015 Annual Quality Assurance Report for the
Radiological Environmental Monitoring Program (REMP)
- FPL/NextEra Energy Nuclear Oversight Vendor Audit Report SBK 14-10 of
Environmental Dosimetry Company/Stanford Dosimetry LLC
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The audits appeared to be thorough and only identified a few minor findings, which
would not have affected any of the analyses submitted to the licensee for its ODCM
program.
The licensee self-initiated a notification (NN 203261419) to assess its environmental
dosimetry program against ANSI N13.37, Environmental Dosimetry - Criteria for
System Design and Implementation. The licensee subsequently contracted the
dosimetry vendor to assess the program as compared to the new American National
Standards Institute (ANSI) standard. The licensee received the vendors assessment
dated December 3, 2015. The licensee is currently evaluating the recommendations,
which include items such as reporting results in millirem instead of milliRoentgen, and
the method used for subtracting background results from environmental dosimeters.
The inspectors observed a chemistry technician perform sample collection in the Units 2
and 3 SFPs on March 23, 2016, using the dip method. The chemistry supervisor
indicated that the monthly sample for each unit is collected using the new SFP island
sink; however, the weekly samples are more easily collected by the dip method. The
inspectors observed good radiation protection (RP) coordination and coverage by the
RP staff, good radiological protection techniques by the chemistry technician, as well as
the necessary foreign material exclusion controls, such as using hard hat chin straps
while obtaining the sample from the SFPs.
e. Groundwater Monitoring
The licensee established 15 groundwater monitoring wells between 2009 and 2012 in
the NIA yard, to sample and monitor groundwater. The wells were established following
the guidelines of the Nuclear Energy Institute NEI 07-07, Groundwater Protection
Initiative. The licensees procedure SO123-IX-1.4.1, Groundwater Monitoring,
Revision 9, provides the guidance for sampling. The analyses are performed by the
licensees contracted environmental analysis laboratory that processes the samples
under the ODCM. The licensee performed quarterly sampling and the results are
documented in the SONGS Annual Radioactive Effluent Release Report. The results
are reviewed by the Groundwater Protection Initiative (GPI) Steering Committee, in
accordance with SO123-GPI-1, Ground Water Protection Initiative.
The inspectors reviewed the last quarterly meeting of the GPI, which occurred on
December 10, 2014. The meeting minutes reflect that the committee reviewed
historical trends of tritium and requested that a plan be developed to terminate the
groundwater protection initiative. As part of the groundwater protection initiative, the
licensee has been extracting groundwater from beneath the site to hydraulically
contain any radioactive fluid plume and to direct the potentially contaminated water to
a monitored release point.
The extraction pumps were turned off on April 28, 2015. The licensee performed
monthly sampling of seven wells between May 2015 and August 2015. The licensee
staff concluded that the temporary suspension of the continuous extraction of
groundwater in the NIA had no effect on the groundwater tritium levels of. The tritium
levels remained consistent with the results before suspension of the extraction wells.
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In addition, the results did not exceed the REMP lower limit of detection of
2000 picoCuries/liter as defined in the ODCM for drinking water. The licensee also
recommended that consideration should be given to placing some additional wells in
the NIA to monitor for any possible migration of tritium created by the ISFSI pad
expansion. The licensee indicated that the results and conclusions will be presented
to the GPI Steering Committee for review and final decision. The licensee also
explained that since the voluntary groundwater initiative was being reduced and
transitioned to a monitoring program, the steering committees quarterly
responsibilities will also be reduced or dissolved.
3.3 Conclusion
The licensees effluent monitoring and environmental monitoring programs were being
conducted in accordance with appropriate regulatory requirements as prescribed by the
4. Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown
Reactors (40801)
4.1 Inspection Scope
The inspectors reviewed the licensees policies and implementing procedures that
govern the corrective action program to verify compliance with the applicable regulatory
requirements and decommissioning documents. Specifically, the inspectors reviewed a
sample of nuclear notifications (NNs) and verified that the NNs disposition and control
provide adequate documentation and description of conditions adverse to quality, as well
as specifying the cause of these conditions and the corrective actions taken to prevent
recurrence.
The inspectors also verified that contractor personnel must submit non-conformance
reports and proposed corrective actions for licensee review, and that the licensee
adequately assessed deficiencies identified or reported by its contractors and entered
them into the corrective action program for tracking. The inspectors also discussed the
corrective action program with licensee management and technical staff.
In addition, the inspectors reviewed the SONGS policies and implementing procedures
that govern the implementation of the internal auditing and decommissioning safety
review programs to verify compliance with the requirements in the DQAP and technical
specifications, and to ensure that significant decommissioning activities are
independently and effectively reviewed.
The inspectors evaluated the effectiveness of licensee controls in identifying, resolving,
and preventing issues that degrade safety or the quality of decommissioning. These
controls include self-assessment, auditing, corrective actions, and root and apparent
cause evaluations. The inspectors reviewed a sample of audit reports and self-
assessments to evaluate compliance with the licensees program and technical
requirements. In addition, the inspectors reviewed the disposition of corrective actions
to resolve deficiencies identified by audit findings for adequacy and timeliness.
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Furthermore, the inspectors discussed the implementation and effectiveness of the audit
and safety review programs with SONGS personnel.
4.2 Observations and Findings
a. Corrective Action Program
The SONGS DQAP establishes the necessary measures to control items, including
services, that do not conform to specified requirements to prevent inadvertent installation
or use, as well as to promptly identify, control, document, classify, and correct conditions
adverse to quality. Non-conformances are evaluated for their impact on the operability
of important-to-safety structures, systems, and components to ensure that the final
condition does not adversely affect safety, operation, or maintenance of the item or
service. The DQAP requires personnel to identify known conditions adverse to quality to
determine what corrective actions are appropriate. Reports of conditions adverse to
quality are analyzed to identify trends. The results of evaluations of conditions adverse
to quality are analyzed, documented, and reported in accordance with applicable
procedures. Significant conditions adverse to quality are documented and reported to
responsible management.
The licensees corrective action program is contained in procedure SO123-XV-50,
Corrective Action Program, Revision 34, which establishes provisions that ensure the
NNs produced as a result of the program provide: 1) adequate documentation and
description of significant conditions adverse to quality; 2) an appropriate analysis of the
cause of these conditions and the corrective actions taken to prevent recurrence;
3) direction for review and approval by the responsible authority; 4) a description of the
current status of the corrective actions; and 5) the follow-up actions taken to verify timely
and effective implementation of the corrective actions. In addition, the procedure
identifies that the timeliness of corrective actions should be commensurate with the
safety significance of the item, and that the extent of corrective actions should be
determined as appropriate for the circumstances.
At SONGS, each NN receives a review during one or more of the management and
safety review committee meetings described in Section 5.2.b, which consist of quality
assurance, health physics, engineering, contractor, and inspection personnel, as
appropriate, evaluating and dispositioning the NNs in accordance with the SONGS
process and documenting the bases for these decisions, as needed. For all NNs, the
management and safety review committees assign appropriate personnel to evaluate
and disposition the NN and provide adequate documentation of these evaluations. The
inspectors attended both, a Management Review Committee (MRC) and a Vendor
Oversight Review Committee (VORC) meeting to verify implementation of the SONGS
corrective action program. It was noted that contractor representatives readily
participated in both meetings. In addition, the licensees attendees were prepared and
knowledgeable of the corrective actions being reviewed.
During the VORC, reported issues were dispositioned into the SONGS corrective action
program for any action determined to be a Level 1 (significant condition adverse to
quality) or Level 2 (condition adverse to quality) significance. For issues identified as
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Levels 3-5 significance, the committee determined whether the issue would be
processed through the licensees corrective action program, or would be processed
through the associated contractors corrective action program. Regardless, the issues
were tracked in the SONGS corrective action program and, once completed, the issue
was closed in both programs.
The inspectors observed that the licensees oversight of the contractors corrective
action programs involved close monitoring, review, and evaluation of each program
using a combination of individual communications, use of the applicable oversight
committees, as well as by the ongoing involvement of the corrective action program
manager. Starting with the implementation of the VORC, the licensee is expected to
continue to identify opportunities for improvement in the oversight of contractor
programs. These efforts can be utilized in the future when overseeing the
decommissioning general contractor.
Finally, the inspectors conducted numerous discussions with SONGS personnel,
including design engineers, quality assurance personnel, and audit representatives, to
verify that all licensee personnel are aware of the corrective action process, recognize
when and how to enter into the process, and understand the types of disposition that can
result from a NN. The inspectors concluded that all of the licensee personnel
interviewed had adequate knowledge of the SONGS corrective action program.
b. Audits and Self-Assessments
The SONGS DQAP establishes the necessary measures to implement audits to verify
that activities covered by the DQAP are performed in conformance with documented
requirements. The audit program is reviewed for effectiveness as part of the overall
audit process. The SONGS DQAP provides for the conduct of periodic internal and
external audits. Internal audits are conducted to determine that the program and
procedures being audited comply with the DQAP. Internal audits are performed with a
frequency commensurate with safety significance and in such a manner as to ensure
that an audit of all applicable quality assurance program elements is completed for each
functional area within a period of 2 years.
External audits determine the adequacy of a supplier's or contractor's quality assurance
program. The licensee ensures that audits are documented and audit results are
reviewed. The licensee also ensures that it responds to all audit findings and initiates
appropriate corrective actions. In addition, where corrective actions are indicated, the
licensee documents follow-up of applicable areas through inspections, review, re-audits,
or other appropriate means to verify implementation of assigned corrective actions.
The inspectors reviewed a sample of internal audits to evaluate the implementation of the
SONGS audit program and verified that the licensee had prepared and approved plans
that identify the audit scope, focus, and applicable criteria before the initiation of the audit
activity. The inspectors confirmed that the audit reports contained a review of the relevant
decommissioning activities and associated documentation. Specifically, the audit forms
were used to verify multiple areas including the environmental program, procedures,
emergency response, external dosimetry, nuclear materials accountability program, and
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air sampling for occupational workers. For audits that resulted in findings the inspectors
verified that the licensee had established a plan for corrective action, that the MRC had
reviewed and approved the corrective action, and then verified its satisfactory completion
and proper documentation.
The inspectors verified that the SONGS DQAP and associated procedures provide
guidance for the indoctrination and training of auditors and lead auditors. These
documents prescribe the minimum experience and training requirements for auditors
and lead auditors and provide that they be certified based on education, experience,
training, examination, audit participation, and communication skills. Each auditor is
trained to the applicable quality assurance procedures, as well as other applicable
nuclear related codes, standards, regulations, and regulatory guides.
The inspectors reviewed a sample of the training and qualification records of the
SONGS auditors and lead auditors and confirmed that auditing personnel had completed
all required training and maintained qualification and certification in accordance with the
licensees policies and procedures. The inspectors also verified that audit teams
selected by the licensee were sufficiently qualified to evaluate areas within the scope of
the audit and that members of the MRC and Nuclear Oversight Board had the necessary
knowledge and experience in areas important to decommissioning.
4.3 Conclusions
The licensee is implementing its corrective action program in accordance with
appropriate regulatory requirements as prescribed by the SONGS DQAP. Based on the
sample of documents reviewed and activities observed, the inspectors determined that
the licensee is successfully implementing its policies and procedures associated with the
corrective action program in accordance with the applicable regulatory requirements,
license conditions, and DQAP procedures.
The licensees auditing and decommissioning safety review programs are being
conducted and maintained in accordance with the appropriate regulatory requirements
as prescribed by the SONGS DQAP. The licensee has established audit, review, and
oversight programs to ensure that activities are being conducted in accordance with the
applicable regulatory requirements, license conditions, and DQAP procedures. These
programs function in a timely, independent, and appropriate manner.
5. Safety Reviews, Design Changes, and Modifications at Permanently Shutdown
Reactors (37801)
5.1 Inspection Scope
The inspectors reviewed the licensees safety review processes, procedures, and
training to verify that the safety review program is effective at contributing to the
protection of public health and safety and the environment. Additionally, the inspectors
reviewed selected design changes and facility modifications to determine if changes,
tests, experiments, and modifications are effectively conducted, managed, and
controlled during plant decommissioning. This inspection verified that major and minor
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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
was adequate to implement the licensees commitments 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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The inspectors reviewed procedure SO123-XXIV-10.1, Engineering Design Control
Process - NECPs, Revision 34, which controls and provides implementation for design
changes, tests, experiments, and modifications. The inspectors determined that the
procedure provided adequate instructions to assure proper implementation, review, and
approval of design changes. The inspectors also verified that when issues were
identified during this process the licensee appropriately documented the issue(s) in the
SONGS corrective action program.
In addition, the inspectors reviewed 13 modification packages that had been installed in
the plant since last NRC inspection activity in August 2015. The inspectors performed
an in-depth review of 3 evaluations performed pursuant to 10 CFR 50.59, and verified
that the evaluations were adequate and prior NRC approval was obtained as
appropriate. Following are the design change packages that were reviewed:
- NECP 801096772, U2 and U3 SFP Level Using Pressure Indication, Revision 1
- NECP 801262260, Transfer Power from Load-center Breaker 3B0711 to
Breaker 2B0711 for Transfer of MCC 3BK, Revision 0
The inspectors reviewed the licensees work activities in Units 2 and 3, which included
removal of systems from service that were no longer required to maintain the integrity of
the reactor coolant pressure boundary, shutdown the reactor, and maintain the reactor in
a shutdown condition. The inspectors confirmed that these activities were completed in
accordance with the licensees safety review processes, even when implemented by
contractor personnel.
b. Management and Safety Review Committees
The overall organizational structure at SONGS is described in the UFSAR, as well as in
Appendix A of the DQAP. The inspectors verified that the licensee maintains an overall
organizational structure that reflects the decommissioning organization described in
these licensing documents. In addition, the licensee continues to manage and
implement several oversight and review committees that establish and maintain effective
oversight of decommissioning activities
The licensee is transitioning towards an organizational structure that allows a contracted
workforce to perform the majority of the decommissioning work activities with
appropriate licensee oversight. For some of the contractor organizations currently
onsite, the contractor maintains an independent training program, radiological coverage
and monitoring procedures, corrective action program, event response procedure,
and/or quality assurance program. In all of these cases the licensee has reviewed and
approved these contractor programs to ensure there is adequate interface with the
licensees program(s) to ensure continued compliance with regulatory requirements and
license conditions.
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The licensee continues to maintain a MRC, Onsite Review Committee, Nuclear
Oversight Board, and has recently implemented a VORC. Licensee Procedures
SO123-XV-60.1, Onsite Review Committee (OSRC), Revision 16, and
SO123-XII-18.17, Nuclear Oversight Board Functions and Responsibilities, Revision 7,
address the responsibilities, composition, qualifications, and functions of these two
organizations and establish the appropriate level of independence to be able to make
recommendations to licensee management. The MRC and VORC charters contain
similar information and all the review committees are used to ensure that both licensee
and contractor staff are performing decommissioning activities in accordance with the
appropriate regulatory requirements, license conditions, and decommissioning
documents.
The inspectors reviewed the meeting minutes of the Onsite Review Committee,
conducted on March 21, 2016, attended a VORC meeting on March 23, 2016, and
attended a MRC meeting on March 24, 2016. In general, the licensee is appropriately
implementing the various oversight committees to ensure that all conditions that could
impact the safety or quality of decommissioning activities at SONGS are being
addressed in a manner commensurate with their potential impact on the overall project.
Specifically, the inspectors noted that implementation of the VORC has established a
robust and through means for collecting and evaluating the non-conformances and
corrective actions reported by the various contractor personnel onsite at SONGS.
Continued use of the VORC will help ensure that the licensees corrective action
program maintains adequate contact with similar contractor programs and that potential
issues are addressed by both licensee and contractor personnel as the
decommissioning projects continue. Finally, the inspectors reviewed the closure of
several corrective actions and other oversight committee items to verify that the licensee
appropriately implemented or resolved the recommendations of the safety review
committees as required by the applicable decommissioning documents.
5.3 Conclusions
The licensees safety review processes, procedures, and training programs are being
conducted and maintained in accordance with the appropriate regulatory requirements
as prescribed by the SONGS DQAP. The licensee has established 10 CFR 50.59
and CFR 72.48 programs to ensure that activities are being conducted in accordance
with the applicable regulatory requirements, license conditions, and DQAP procedures.
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.
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 has established additional oversight and
controls for contractor programs to ensure that activities are being conducted in
accordance with the applicable regulatory requirements, license conditions, and DQAP
procedures.
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6. Operation of an Independent Spent Fuel Storage Installation (60855)
6.1 Inspection Scope
A routine inspection was conducted of the SONGSs ISFSI to verify ongoing compliance
with the Transnuclear (TN) Certificate of Compliance (CoC) No. 1029, Amendment 1
and its associated Technical Specifications, the TN Standardized Advanced Nuclear
Horizontal Modular Storage (NUHOMS) Systems UFSAR, Revision 3 and the
regulations in 10 CFR Part 20 and Part 72.
6.2 Observations and Findings
The inspectors performed a paperwork review of documents related to dry fuel storage
operations, including licensee performed quality assurance audits and surveillances,
ISFSI and fuel building crane related condition reports, cask maintenance records, ISFSI
monitoring data and surveillance records, and TN CoC No. 1029 Technical Specification
(TS) for temperature and ventilation surveillance records. In addition, the inspectors
performed an inspection of the SONGS ISFSI pad to assess its condition and the
condition of the spent fuel storage casks, and verified the radiation levels onsite, the
inspectors spent a day observing spent fuel assembly sipping operations in the Unit 3
spent fuel building.
Six ISFSI related audit reports were issued since the last ISFSI inspection in
January 2014. Those reports covered programs, such as Nuclear Regulatory Affairs,
RP, Procurement and Material Control, Security and Safeguards, and Fire Protection.
The audits resulted in two minor ISFSI related condition reports that were placed into the
licensee's corrective action program for final resolution.
The inspectors reviewed a quality assurance surveillance report which chronicled the
SONGS Nuclear Oversight Department's observation of a routine ISFSI maintenance
activity: verifying the torque of the door attachment bolts for 10 of the 51 loaded
advanced horizontal storage modules (AHSMs). No problems were noted during that
evolution. In addition, the inspectors reviewed three vendor quality assurance
surveillance reports. One of the reports was a Nuclear Procurement Issues Committee
(NUPIC) joint audit of Holtec International, including its facilities located in Marlton, New
Jersey; Holtec Manufacturing Division in Turtle Creek, Pennsylvania; Orrvilon facility in
Orrville, Ohio; and the Nanotec facility in Lakeland, Florida. This audit did not include
any items designed for use in the Holtec International HI-STORM UMAX ISFSI that is
planned for construction at SONGS beginning this year.
The second vendor surveillance was a facility assessment report for the Holtec Orrvillon
and Holtec Manufacturing Division facilities. The facility assessment report documented
a pre-surveillance visit by the licensee to the two Holtec fabrication facilities to determine
which steps in the fabrication process would be best to concentrate its inspection efforts
during the manufacturing of the 73 multi-purpose canisters (MPCs), Holtec
Model MPC-37s, that will be required for the storage of spent fuel in the proposed
Holtec HI-STORM UMAX ISFSI at SONGS.
- 23 -
Lastly, the inspectors reviewed a Source Verification Report for SONGSs current ISFSI
vendor, TN. The licensee sent an auditor to surveil numerous steps in the fabrication
process of six TN DSC-32 Model Dry Shielded Canisters, DSC-32-001 through
DSC-32-006. Although purchased by the licensee, the six DSC-32s will never be used
at SONGS. The 2,668 spent fuel assemblies remaining in the Units 2 and 3 spent fuel
pools will all be stored in the proposed HI-STORM UMAX ISFSI, once it has been
constructed and its licensing has been completed. No significant deficiencies were
identified in any of the vendor surveillance reports reviewed by the NRC inspectors.
The licensee provided a list of ISFSI and fuel building crane related NNs issued since
the last NRC inspection (January 2014) to the inspectors. The inspectors selected 27
for further review. The inspectors determined that the NNs were well documented and
properly categorized based on the safety significance of the identified condition. All
follow-up corrective actions were appropriately assigned. Based on the types of
conditions described in the NNs, the licensee demonstrated a suitably low threshold for
placement of issues into its corrective action program. Based on the NNs reviewed, the
NRC concluded that the licensee demonstrated good attention to detail in regards to the
operation and routine maintenance of its ISFSI program and the fuel building crane. No
significant trends or safety concerns were identified during the review of the corrective
action program. The licensee identified conditions were processed in accordance with
Procedure SO123-XV-50.
The inspectors attended both the managers daily turnover meeting and the craft
technical turnover briefing for the ongoing Unit 3 fuel sipping and inspection operations.
The licensee began its fuel sipping operations on December 1, 2015, in the Unit-2 fuel
handling building SFP. The Unit 2 fuel sipping operations concluded in February 2016.
Fuel sipping in the Unit 3 SFP began on February 23, 2016, and was scheduled to
continue until the end of April 2016. Fuel sipping is a method to determine whether a
fuel assembly shows evidence of cladding failure through the detection of trapped
radioactive fission product gases that are pulled out of the fuel after being subjected to a
pressure differential. In addition to the sipping operations, the fuel assemblies were also
visually inspected for irregularities, debris, and other damage.
At the time of the NRC visit, fuel assembly sipping and inspection were taking place
Monday through Thursday, while Fridays were set aside for visual inspections only. As
of March 8, 2016, the fuel assemblies to date had a failure rate of roughly 1 percent.
The number of cladding defects identified in the Unit 2 SFP were 10 out of a total
of 1,318 fuel assemblies tested.
During the evening of March 7, 2016, the Unit 3 fuel bridge crane experienced
operational problems in its ability to traverse the SFP. The licensee described the
problem as crabbing, where the fuel bridge crane did not travel smoothly. As a result,
the fuel bridge crane was declared inoperable and all fuel movements were suspended
until the fuel bridge crane could be repaired. During the temporary stoppage of SFP
operations, an NRC inspector was provided access to the fuel movers and craft
technicians performing the fuel sipping operations for questions. There are several
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types of fuel sipping operations that can take place at various times during a reactors
operation. The type of sipping being performed at SONGS was Westinghouse Canister
Sipping.
In canister sipping, a fuel assembly is placed into a cylindrical vessel at the bottom of the
SFP. Spacers are used in the vessel such that the fuel assembly is raised to a standard
height inside of the cylinder before it is sealed off. Once sealed, a volume of air is blown
into the cylinder to form a space over the fuel assembly. It should be noted that the fuel
assembly is always covered with water from the SFP. Next, a vacuum is applied to the
air space over the fuel assembly, providing the pressure differential to liberate any
trapped fission gases from the fuel through cracks or other fissures. The vacuum is
drawn through a sodium iodide scintillation detection crystal, which is where the
radioactive gases are detected. The gas is recirculated through the system, which, in
theory, allows for improved detection efficiency because any of the gases pulled from
the failed fuel will concentrate and not escape the closed loop system. Once a failed
fuel element is detected, the system is secured to prevent contamination of the detector.
The canister sipping set-up used at SONGS employed dual cylinders and two identical
detector systems installed in parallel to improve throughput.
An NRC inspector was invited to enter the fuel building with the fuel sipping technicians
who demonstrated their preoperational setup procedure with the specialized fuel sipping
equipment and answered multiple questions raised by the inspector. The technicians
were eager to provide answers to the wide variety of questions raised by the inspector.
These questions specifically were about their unique equipment, differences in fuel
sipping technology, and their experiences and expectations while sipping older fuel
assemblies.
The fuel bridge crane had been repaired and fuel sipping operations recommenced by
March 8, 2016. An NRC inspector observed approximately six fuel assemblies being
sipped. None of the ones observed during the sipping process were found to be leakers.
However, several instances of foreign materials were found on fuel assemblies by the
inspector and were noted. Each fuel assembly inspection was recorded with video
cameras and several still photographs of debris on fuel assemblies were taken and
cataloged for record keeping purposes.
All of the fuel movements were carefully performed. The fuel bridge crew employed
three-way communications between the fuel movers, persons tracking fuel assembly
selection, and fuel sipping technicians. The NRC inspector did not identify any safety
related issues during the observed operations.
The inspectors verified the radiological conditions of the SONGS ISFSI through a review
of TLD direct radiation monitoring data, the most recent radiological survey, and a tour of
the ISFSI pad with a radiation survey meter. An inspector was accompanied by an
RP Manager and an ISFSI Program Manager during the inspection of the ISFSI pad.
The ISFSI pad was securely fenced and locked inside a separate protected area outside
of the reactor site's protected area. The ISFSI was clear of any notable vegetative
growth and there were not any combustible, flammable, or unexpected items present on
the storage pad. The ISFSI pad contained 63 TN AHSMs, 51 of them loaded
- 25 -
and 12 empty. All of the AHSMs were in good physical condition. Measurements were
taken in close proximity to the loaded casks by the RP technician with a Bicron
MicroRem tissue-equivalent survey meter (S/N C881C, calibration due May 30, 2016) to
record gamma dose rates in microrem per hour (µrem/h). The highest level observed in
a random sampling of AHSMs was 500 µrem/h. The measurements taken by the RP
technician confirmed the measurements recorded on the most recent ISFSI site survey.
The NRC inspector carried a Ludlum Model 19 sodium-iodide gamma survey meter
(NRC #016337, calibration due August 6, 2016) to record gamma exposure rates in
microRoentgens per hour (µR1/h). The inspector recorded radiation levels ranging
from 12 - 48 µR/h at the ISFSI fence boundary locations.
The radiological conditions in and around the ISFSI were as expected, given the initial
heat loads of the spent fuel, time spent on the pad, and storage configuration of the
spent fuel in the SONGS ISFSI. The ISFSI was properly posted as a radioactive
materials area. To review the contents of the SONGS ISFSI, see the previous NRC
inspection report for this site (ML14045A317).
The direct radiation monitoring TLD data for the ISFSI was reviewed for the current and
previous two years. The TLD monitoring results documented a decrease in radiation
dose in close proximity to the ISFSI pad as the spent fuel contents continued to cool and
decay. No additional spent fuel has been placed into the SONGS ISFSI since 2012.
Annual REMP data documented the dose equivalent to any real individual located
beyond the site controlled area was well below the 10 CFR 72.104(a)(2) requirement
of less than 25 millirem (mrem) per year. Annual monitoring data near the ISFSI
boundary locations show that accessible areas of the ISFSI also fall below
the 10 CFR 20.1502(a)(1) dose limit for unmonitored individuals, which is 500 mrem
per year. Direct radiation impacts from the SONGS ISFSI met all regulatory
requirements.
The NRC inspectors reviewed three randomly selected weeks of TN AHSM temperature
surveillance records to ensure that the TN CoC 1029 Technical Specification 5.2.5
requirements were being met for fuel stored on the ISFSI pad. The information provided
by the licensee was complete.
6.3 Conclusion
The inspectors observed that the licensee had met the licensing requirements for the
documents and activities reviewed associated with the dry cask storage activities at
1
For the purposes of making comparisons between NRC regulations based on dose-equivalent (rem) and
measurements made in Roentgens, it may be assumed that one Roentgen equals one rem.
(http://www.nrc.gov/about-nrc/radiation/protects-you/hppos/qa96.html)
- 26 -
7. Review of 10 CFR 72.212(b) Evaluations (60856)
7.1 Inspection Scope
The 10 CFR 72.212 Evaluation Report was reviewed to verify site characteristics were
still bounded by the TN NUHOMS System design basis.
7.2 Observations and Findings
The licensee was operating under Revision 9 of its 10 CFR 72.212 Evaluation Report,
the same as during the previous ISFSI inspection. Since the last inspection, however,
two 10 CFR 72.48 screens were performed for editorial changes to the 10 CFR 72.212
Evaluation Report. Those changes were documented in the form of the licensee's
Engineering Change Notice/Calculation Change Notice (ECN/CCN) process, instead of
a report revision.
7.3 Conclusions
The licensee was maintaining the 10 CFR 72.212 Evaluation Report current as required.
Two changes to the 10 CFR 72.212 report had been made since the last NRC ISFSI
inspection in 2014. No issues were found associated with the ECN/CCN documentation
regarding those changes.
8. Review of 10 CFR 72.48 Evaluations (60857)
8.1 Inspection Scope
The licensees 10 CFR 72.48 screenings and evaluations since the 2014 NRC ISFSI
inspection were reviewed to determine compliance with regulatory requirements
8.2 Observations and Findings
The licensees 10 CFR 72.48 screens and evaluations for changes to the ISFSI program
since the last NRC inspection were reviewed to determine compliance with regulatory
requirements. Two 10 CFR 72.48 screens and no full 10 CFR 72.48 evaluations had
been performed since the last SONGS inspection. The licensee had not performed
any 10 CFR 50.59 screens or safety evaluations for the fuel building cask handling crane
since the last inspection.
8.3 Conclusions
All required screens and safety evaluations had been performed in accordance with
procedures and 10 CFR 72.48 requirements. All of the 10 CFR 72.48 screens that were
reviewed were determined to have been adequately evaluated by the licensee.
- 27 -
9. Follow Up of Events
9.1 (Closed) Licensee Event Report (LER) 05000361/2015-002-00, Spent Fuel Pool
Temperature Drifted Below Updated Final Safety Analysis Report (UFSAR) Value
a. Inspection Scope
On November 19, 2015, the licensee determined that the SONGS Unit 2 SFP
temperature had drifted approximately two degrees below the analyzed temperature
of 68°Fahrenheit (°F) on several previous days. Based on a review of operation logs
and other available data, the licensee identified 41 days for Unit 2 and 45 days for Unit 3
during which the temperature fell below the analyzed value. The typical drift was up
to 2 degrees below 68°F, with the lowest recorded temperature of approximately 61°F
one time for Unit 2 and Unit 3.
The licensee evaluated and analyzed a new lower temperature limit for the spent fuel
pools using an updated spent fuel criticality calculation that modified the existing input
data to be consistent with the current situation for the SFPs at SONGS. The revised
calculation established a new lower temperature limit of 50°F. The SONGS UFSAR,
Section 9.1.2.3, Safety Evaluation, was updated to document the spent fuel pool
temperature range being acceptable from 50°F to 160°F.
The licensee determined that the cause for the low SFP temperatures was the reduced
heat load in the facility coupled with low ocean temperatures. Each SFP is cooled by
each units component cooling water system, which is cooled by the Pacific Ocean.
Since there are no longer other plant loads, there is not a significant difference between
the SFP temperatures and the ocean temperature, as there was when the facility was
operating. Therefore, the SFP temperatures have decreased and are more affected by
changes in the ocean temperature.
The licensee has noted and the inspectors confirmed that with the operation of the new
independent spent fuel pool cooling system for each unit, the temperature of the SFPs
will be able to be held at a constant temperature. In addition, the inspectors verified that
the lower analyzed temperature limit of 50°F did not have a safety significant impact on
the spent fuel cladding material properties.
b. Conclusions
LER 05000361/2015-002-00, Spent Fuel Pool Temperature Drifted Below Updated
Final Safety Analysis Report (UFSAR) Value is closed with no findings identified.
10. Exit Meeting Summary
On March 10, 2016, and March 24, 2016, the NRC inspectors presented the inspection
results to SCE management and staff. There was no proprietary information provided to
the inspectors.
- 28 -
SUPPLEMENTAL INSPECTION INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J.Kay, Manager, Regulatory Affairs
G.Lemon, Project Manager
S.Vaughan, Project Manager
V.Barone, Project Manager, Engineering
B.Metz, Environmental Manager
M.Reitzler, Maintenance
S.Hoque, Chemistry Supervisor
J.Davis, Operations Manager
M. Moran, Site Engineering
J.Peattie, Maintenance and Work Control
M.Morgan, Regulatory Affairs
J.Appel, Regulatory Affairs
N.Mascolo, Manager, Natural Resources and Public Lands
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
05000361/2015-002-00 LER Spent Fuel Pool Temperature Drifted Below Updated Final
Safety Analysis Report (UFSAR) Value (Section 9.1)
Discussed
None
A-1 Attachment
LIST OF ACRONYMS
ADAMS Agencywide Documents Access and Management System
AHSM advanced horizontal storage module
ANSI American Nuclear Standards Institute
CCN Calculation Change Notice
CFR Code of Federal Regulations
CoC Certificate of Compliance
DSC dry shielded canister
DQAP Decommissioning Quality Assurance Program
ECN Engineering Change
GPI groundwater protection initiative
IP Inspection Procedure
ISFSI Independent Spent Fuel Storage Installation
LER Licensee Event Report
MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual (NUREG-1575)
MPC multi-purpose canister
MRC Management Review Committee
NEI Nuclear Energy Institute
NIA north industrial yard
NN nuclear notification
NUPIC Nuclear Procurement Issues Committee
ODCM Offsite Dose Calculation Manual
OSRC Onsite Review Committee
PSDAR Post-Shutdown Decommissioning Activities Report
RP radiation protection
REMP Radiological Environmental Monitoring Program
S/N serial number
SFP spent fuel pool
TLD thermoluminescent dosimeter
TN Transnuclear
TS Technical Specifications
UFSAR Updated Final Safety Analysis Report
VORC Vendor Oversight Review Committee
A-2
T. Palmisano -2-
In accordance with 10 CFR 2.390, Rules of Practice and Procedure, a copy of this letter will be
available electronically for public inspection in the NRCs Public Document Room or from the
Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access
and Management System (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Jack E. Whitten, Chief
Fuel Cycle & Decommissioning Branch
Division of Nuclear Materials Safety
Docket Nos. 50-361; 50-362; and 72-041
Enclosure:
Inspection Report 05000361/2016001;
05000362/2016001; 07200041/2016001
w/Attachment: Supplemental Information
Distribution
See next page
ADAMS Accession Number: ML16127A580
SUNSI Review: RSB ADAMS: Publicly Available Non-Sensitive Keyword: NRC-002
Yes No Non-Publicly Available Sensitive
OFFICE DNMS/FCDB DNMS/FCDB DNMS/FCDB NMSS/ C:FCDB
NAME RSBrowder ESimpson REvans MValler JWhitten
SIGNATURE /RA/ /RA/ n/a email /RA/
DATE 5/3/16 5/3/16 --- 5/3/16 5/5/16
OFFICIAL RECORD COPY
Letter to Thomas J. Palmisano from Jack Whitten dated May 5, 2016
SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION
REPORTS 05000361/2016001; 05000362/2016001 AND 07200041/2016001
DISTRIBUTION
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)
DNMS Director (Mark.Shaffer@nrc.gov)
DNMS Deputy Director (Linda.Howell@nrc.gov)
Branch Chief, DNMS/FCDB (Jack.Whitten@nrc.gov)
Senior Health Physicist, FCDB (Robert.Evans@nrc.gov)
Senior Health Physicist, FCDB (Rachel.Browder@nrc.gov)
Health Physicist, FCDB (Eric.Simpson@nrc.gov)
RIV Public Affairs Officer (Victor.Dricks@nrc.gov)
NMSS/DUWP/RDB Project Manager (Marlayna.Vaaler@nrc.gov)
Branch Chief, NMSS/DUWP/RDB (Bruce.Watson@nrc.gov)
RIV RITS Coordinator (Marisa.Herrera@nrc.gov)
RIV Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)
RIV/ETA: OEDO (Jeremy.Bowen@nrc.gov)
RIV RSLO (Bill.Maier@nrc.gov)
Mr. Jim Kay, Regulatory Affairs Mr. Gonzalo Perez, Branch Chief
Southern California Edison Company Radiologic Health Branch
San Onofre Nuclear Generating Station Div of Food, Drug, & Radiation Safety
P.O. Box 128 CA Dept. of Health Services
San Clemente, CA 92674-0128 P.O. Box 997414, MS 7610
Sacramento, CA 95899-7414
Mr. Lou Bosch, Plant Manager Dr. Robert B. Weisenmiller, Chair
Southern California Edison Company California Energy Commission
San Onofre Nuclear Generating Station 1516 Ninth Street (MS 34)
P.O. Box 128 Sacramento, CA 95814
San Clemente, CA 92674-0128
Mr. W. Matthews III, Esquire
Southern California Edison Company
Law Department
2244 Walnut Grove Avenue
Rosemead, CA 91770