ML23046A379

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NRC Inspection Report 050-00361/2023-001 and 050-00362/2023-001
ML23046A379
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 02/22/2023
From: Greg Warnick
NRC/RGN-IV/DRSS/DIOR
To: Bauder D
Southern California Edison Co
References
IR 2023001
Download: ML23046A379 (15)


See also: IR 05000361/2023001

Text

February 22, 2023

Doug Bauder

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

REPORT 050-00361/2023-001 AND 050-00362/2023-001

Dear Doug Bauder:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on

January 23-26, 2023, at the San Onofre Nuclear Generating Station, Units 2 and 3. This

inspection examined activities conducted under your license as they relate to public health and

safety, the common defense and security, and to confirm compliance with the Commissions

rules and regulations, and with the conditions of your licenses. Within these areas, the

inspection consisted of selected examination of procedures and representative records,

observations of activities, performance of independent radiation measurements, and interviews

with personnel.

Specifically, the inspectors reviewed decommissioning activities in progress at Units 2 and 3,

solid radioactive waste management and transportation of radioactive material, and remedial

and final status surveys. The inspectors discussed the results of the inspection with you and

members of your staff during the final exit meeting on January 26, 2023. The inspection results

are documented in the enclosure to this letter. Within the scope of the inspection, no violations

were identified, and no response to this letter is required.

During the onsite inspection, staff from the Oak Ridge Associated Universities, Oak Ridge

Institute for Science and Education conducted a confirmatory survey of the two intake structures

on behalf of the NRC. The results of the confirmatory survey were not available at the end of the

onsite inspection and will be presented to you under separate correspondence.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a

copy of this letter, the enclosure, and your response if you choose to provide one, will be made

available electronically for public inspection in the NRC Public Document Room or from the

NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is

accessible from the NRCs Website at http://www.nrc.gov/reading-rm/adams.html. To the extent

possible, your response should not include any personal privacy or proprietary, information so

that it can be made available to the Public without redaction.

D. Bauder

2

If you have any questions regarding this inspection report, please contact Dr. Robert Evans at

817-200-1234, or the undersigned at 817-200-1249.

Sincerely,

Gregory G. Warnick, Chief

Decommissioning, ISFSI, and Operating

Reactor Branch

Division of Radiological Safety and Security

Docket Nos. 50-361; 50-362

License Nos. NPF-10; NPF-15

Enclosure:

Inspection Report 050-00361/2023-001;

050-00362/2023-001

w/Attachment: Supplemental Inspection Information

Distribution via Listserv

Signed by Warnick, Gregory

on 02/22/23

ML23046A379

SUNSI Review

By: RJE

ADAMS:

Yes

No

Sensitive

Non-Sensitive

Non-Publicly Available

Publicly Available

Keyword

NRC-002

OFFICE

DRSS/DIOR

NMSS/DUWP/URMDB

C:DIOR

NAME

RJEvans

LMGersey

GGWarnick

SIGNATURE

/RA/

/RA/

/RA/

DATE

02/16/23

02/16/23

02/22/23

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.

050-00361; 050-00362

License Nos.

NPF-10; NPF-15

Report Nos.

050-00361/2023-001; 050-00362/2023-001

Licensee:

Southern California Edison Company

Facility:

San Onofre Nuclear Generating Station, Units 2 and 3

Location:

5000 South Pacific Coast Highway

San Clemente, California

Dates:

January 23-26, 2023

Inspectors:

Robert J. Evans, PhD, CHP, PE, Senior Health Physicist

Decommissioning, ISFSI, and Operating Reactor Branch

Division of Radiological Safety and Security

Linda M. Gersey, Health Physicist

Decommissioning, ISFSI, and Operating Reactor Branch

Division of Radiological Safety and Security

Accompanied By:

Troy Johnson, Health Physicist

Decommissioning, ISFSI, and Operating Reactor Branch

Division of Radiological Safety and Security

Eric McManus, Health Physicist

Decommissioning, ISFSI, and Operating Reactor Branch

Division of Radiological Safety and Security

Approved By:

Gregory G. Warnick, Chief

Decommissioning, ISFSI, and Operating Reactor Branch

Division of Radiological Safety and Security

Attachment:

Supplemental Inspection Information

2

EXECUTIVE SUMMARY

San Onofre Nuclear Generating Station, Units 2 and 3

NRC Inspection Report 05000361/2023-001; 05000362/2023-001

This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced

inspection of decommissioning activities being conducted at the San Onofre Nuclear Generating

Station (SONGS), Units 2 and 3. In summary, the licensee and its decommissioning contractor

were conducting activities in accordance with site procedures, license requirements, and

applicable NRC regulations.

Decommissioning Performance and Status Review at Permanently Shutdown Reactors

The licensee and its decommissioning contractor were conducting decommissioning

activities in accordance with the instructions provided in the Post Shutdown

Decommissioning Activities Report and site procedures. Radiological controls and related

postings were being maintained. (Section 1.2)

Solid Radioactive Waste Management and Transportation of Radioactive Materials

The licensees decommissioning contractor was conducting reactor vessel internal

segmentation work involving greater-than-Class C material in accordance with approved

work plans and liner loading procedures. (Section 2.2.a)

The contractor conducted waste management and transportation activities in accordance

with the Post Shutdown Decommissioning Activities Report and site procedures.

(Sections 2.2.b and 2.2.c)

The contractor identified a shipment that contained radioactive contaminated material that

was in process to be released from the site. The contractor took prompt corrective actions in

response to the event. (Section 2.2.d)

Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors

The licensees contractor designed and conducted remedial action support surveys in

accordance with procedural requirements and with NRC guidance documents.

(Section 3.2.a)

The inspectors concluded that the licensee had developed and implemented a final status

survey program that was generally consistent with NRC guidance. (Section 3.2.b)

A contractor conducted confirmatory surveys on behalf of the NRC. The results of the

confirmatory survey will be presented to the licensee under separate correspondence.

(Section 3.2.c)

3

Report Details

Summary of Plant Status

On June 12, 2013, the Southern California Edison Company, the licensee, formally notified

the NRC that it had permanently ceased power operations at SONGS, Units 2 and 3, effective

June 7, 2013 (Agencywide Documents Access and Management System [ADAMS]

Accession No. 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 the Units 3 and 2 reactor vessels as of October 5, 2012, and July

18, 2013, respectively. The NRC subsequently 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.

As required by Title 10 the Code of Federal Regulations (10 CFR) 50.82(a)(4), the licensee

submitted its Post Shutdown Decommissioning Activities Report (PSDAR) to the NRC on

September 23, 2014 (ML14269A033). The PSDAR outlines the planned decommissioning

activities. The current version of the PSDAR is dated May 7, 2020 (ML20136A339). The

licensee chose to implement the decommissioning alternative DECON. DECON is the removal

or decontamination of equipment, structures, or portions of the facility and site that contain

radioactive contaminants to levels that permit termination of the license.

On December 20, 2016, the licensee announced the selection of AECOM and EnergySolutions

as the decommissioning general contractor. The joint venture between the two companies was

called SONGS Decommissioning Solutions (SDS). The SDS organization manages most

decommissioning activities as described in the PSDAR.

By letter dated August 7, 2020 (ML20227A044), the licensee certified that all spent fuel was

removed from both Units 2 and 3. Accordingly, SONGS entered their Independent Spent Fuel

Storage Installation (ISFSI) Only Technical Specifications, Emergency Plan, and Security Plan

on August 10, 2020. After removal of all spent fuel from the two units, SDS started

decommissioning work within the two containment buildings and spent fuel pool (SFP) rooms.

During the inspection week, the activities in progress included segmentation of the reactor

vessel internals inside the two containments. The decommissioning contractor was also

preparing the two containments for future removal of large components. In addition, the

contractor was removing hot spots and conducting remedial activities within the radwaste

building, removing the fuel racks from the Unit 2 SFP, and demolishing the Unit 3 turbine

building. Finally, the contractor was conducting radiological surveys in the Units 2 and 3 intake

structures for future release.

1

Decommissioning Performance and Status Review at Permanently Shutdown

Reactors (Inspection Procedure 71801)

1.1

Inspection Scope

The objectives of this portion of the inspection effort were to evaluate the status of

decommissioning and to verify whether the licensee was conducting decommissioning

and maintenance activities in accordance with regulatory and license requirements.

4

1.2

Observations and Findings

Section II.A of the PSDAR provides a description of the decommissioning periods. The

site is currently in Period 4. Period 4 begins with the completion of fuel transfer

operations and extends through the end of the decommissioning and decontamination

work. At the time of the inspection, the licensee and its decommissioning general

contractor SDS were conducting decommissioning activities in accordance with the

general guidance provided in Section II.B.1 of the PSDAR. The inspectors discussed the

current schedule with decommissioning management staff and conducted site tours to

observe work in progress.

The contractor was actively segmenting the reactor vessel internals in both

containments. The vessel internals were being segmented, in part, to separate the

greater-than-Class C (GTCC) wastes from the remainder of the material. The GTCC

wastes were being loaded into storage liners and will eventually be transferred and

stored at the onsite Independent Spent Fuel Storage Installation (ISFSI). The remainder

of the vessel internals will be packaged for disposal as radioactive wastes.

At the time of the inspection, there were two reactor vessel internals volume reduction

stations in service in each of the two units. In Unit 2, the contractor was actively cutting

the upper guide structure fuel alignment plate at one station and the core shroud core

plate at the other station. In Unit 3, the contractor was cutting the upper guide structure

core plate at one station and the core support barrel D-ring at the other station. The

inspectors reviewed the approved work packages for the work in progress and

interviewed the staff who were conducting the work. The inspectors concluded that the

contractors were conducting the work in accordance with approved procedures.

The inspectors toured the Unit 2 and Unit 3 containments and observed the work in

progress. The work included cutting of interferences for future removal of large

components and staging of contaminated equipment and radioactive trash for future

removal and disposal. Housekeeping was adequate in both containments, and the

radiological controls were consistent with regulatory requirements in the two restricted

areas.

Section II.B.3 of the PSDAR provides a description of the planned decommissioning and

dismantlement activities. Material with contamination below the applicable radiological

limits may be released for unrestricted disposition including recycling, while radioactive

contaminated material will be packaged and shipped to a low-level waste disposal

facility. The Unit 2 turbine building had been essentially demolished prior to the onsite

inspection. In addition, the gantry crane on the Unit 3 turbine building was permanently

removed from service prior to the onsite inspection. The work in progress during the

inspection included demolition of the Unit 3 turbine building. The contractor was

separating the metal from the concrete debris for recycling. The concrete was being

packaged and disposed as very low-level radioactive waste. During the inspection, the

contractor was crushing concrete and loading the crushed material into rail cars for

transportation to the disposal site. The inspectors noted that the decommissioning work

was being conducted with an emphasis on personnel safety.

The inspectors conducted independent radiological surveys during plant tours using a

Radeye G gamma survey meter (serial number 30932, calibrated to cesium-137 with a

calibration due date of November 9, 2023). The inspectors validated that the licensee

5

had properly posted the radiological areas that were toured. No high radiation area was

identified that was not already posted and controlled. No radiation areas were identified

outside of the radiologically restricted and posted areas.

1.3

Conclusion

The licensee and its decommissioning contractor were conducting decommissioning

activities in accordance with the instructions provided in the PSDAR and site

procedures. Radiological controls and related postings were being maintained.

2

Solid Radioactive Waste Management and Transportation of Radioactive Material

(Inspection Procedure 86750)

2.1

Inspection Scope

The purposes of this portion of the inspection were to verify the effectiveness of the

licensees and its decommissioning contractors programs for processing, handling,

storage, and transportation of radioactive material.

2.2

Observations and Findings

a.

Review of GTCC Work in Progress

Section II.B.1 of the PSDAR states that the reactor vessel internals will be removed and

segmented as necessary to separate the GTCC wastes. The GTCC wastes will be

placed in storage canisters for eventual storage at the onsite ISFSI. The inspectors

reviewed the status of the GTCC work.

The contractor developed loading plans for each of the 10 liners, five per unit, that will be

filled with GTCC material. The reactor vessel internals were being segmented in

accordance with approved cutting plans. The material containing GTCC was segregated

from the rest of the material. The liners, when filled, will eventually be packaged in a

canister. The 10 canisters will be transferred to the onsite ISFSI for storage.

At the time of the inspection, one liner was located in the Unit 2 reactor cavity, while two

liners were located in the Unit 3 reactor cavity. Material containing GTCC wastes was

being placed into the liners or staged adjacent to the liners. The contractor plans to start

removing liners containing GTCC material from the reactor cavities in March 2023. The

inspectors concluded that the licensees contractor was conducting work in accordance

with approved segmentation work plans and liner loading procedures.

b.

Review of SFP Rack Removal and Shipment Activities

The PSDAR,Section II.B.1, states that one of the major decommissioning activities to be

conducted includes removal and disposal of the spent fuel storage racks. The inspectors

reviewed the status of the rack removal work from the two SFPs. The Unit 2 pool had

been drained to just above the top of the spent fuel racks. The decommissioning

contractor had removed, packaged, and shipped the first of six racks. The inspectors

reviewed the shipping manifest for the first shipment. The second rack was staged

onsite for shipment. The inspectors also observed the movement of the third rack.

6

The inspectors observed radiation protection surveys and pressure washing of the

suspended fuel rack for gross contamination removal. A contractor representative

walked the inspectors through the procedure to remove, decontaminate and package

fuel racks for shipment. The inspectors observed final packaging and the contractors

inspection of the second fuel rack as it was being prepared for subsequent loading onto

a shipping trailer. The inspectors reviewed two partially completed work packages for the

second and third racks. Based on the work observed and discussion with site staff, the

inspectors concluded that the contractor was conducting work in accordance with

approved procedures.

After all racks have been removed from the Unit 2 SFP, the contractor plans to start

removing the racks from the Unit 3 SFP. Following removal of all racks, the remainder of

the pool water from the two pools will be drained, processed, and released in

accordance with the Offsite Dose Calculation Manual.

c.

Review of Shipment Activities

During routine tours, the inspectors observed the status of radioactive material

containers and area postings. Outside of the Unit 2 containment building, the inspectors

observed the removal of the impact limiters from a waste container that was staged on a

trailer. The trailer had recently arrived at the site. The inspectors noted that the work

supervisor demonstrated an understanding of the work procedure with an intent to

perform the required radiological surveys upon removal of the impact limiter

components.

The inspectors also validated that staged rail cars were marked and labeled as empty

containers, in accordance with the U.S. Department of Transportation regulations. The

inspectors observed operations during loading of a rail car with crushed concrete

material from the Unit 2 turbine generator building demolition. The contractor controlled

all crushed concrete as radioactive material in accordance with site procedures. The

inspectors observed the safe control of the area while heavy equipment was in use, and

the inspectors validated that the labels and postings were correctly updated after the

crushed concrete was loaded into car.

The inspectors also observed the operation of the truck/trailer monitoring station prior to

allowing vehicle entry into the sites controlled area. Discussions with the radiation

protection technician validated his understanding of the operating procedures and

knowledge of actions required in the event of either a valid or false monitoring alarm.

d.

Review of Recent Incident involving Contaminated Wastes

The inspectors reviewed a recent incident in which radioactive material was identified in

a shipment being released from the site. Site procedures specify that prior to shipment of

demolition debris, an aggregate check of the shipment using a radiological survey

instrument must be performed and an evaluation of the load must also be performed

using the truck monitor at the site exit. Material and equipment shall not be released

from radiological controls if they are contaminated with plant-related radioactive material

that is distinguishable from background. This two-step survey process was implemented,

in part, to help prevent the accidental release of contaminated material.

7

In mid-December 2022, during a routine survey of a truck load of scrap material

preparing for release, an aggregate radiological check of the load identified radioactive

material that was distinguishable from background. The truck returned to the restricted

area for offloading, and radioactive contaminated piping was identified in the load. The

piping was determined to be radwaste discharge piping that was improperly marked. The

remaining debris piles were scanned for radioactivity and the recovered piping was

properly dispositioned as radioactive material.

In summary, the contractors procedural control and field survey of radioactive material

was effective in that it successfully identified contaminated piping in a shipment that was

prepared to leave the site. The contractor took appropriate corrective actions including

issuance of a condition report (SDS-001547) to determine the causes of the incident and

formulation of steps necessary to prevent recurrence of the event.

2.3

Conclusion

The licensees decommissioning contractor was conducting reactor vessel internal

segmentation work involving GTCC material in accordance with approved work plans

and liner loading procedures. The contractor conducted waste management and

transportation activities in accordance with the PSDAR and site procedures. The

contractor identified a shipment that contained radioactive contaminated material that

was in process to be released from the site. The contractor took prompt corrective

actions in response to the event.

3

Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors

(Inspection Procedure 83801)

3.1

Inspection Scope

To verify that the licensee has decontaminated the Units 2 and 3 intake structures to

acceptable residual radioactivity levels for unrestricted use, as specified in Subpart E,

Radiological Criteria for License Termination, to 10 CFR Part 20, Standards for

Protection Against Radiation.

To verify that the licensees implementing procedures, radiological measurements,

decommissioning surveys, and documentation of decommissioning surveys for the Unit

2 and 3 intake structures comply with approved site procedures.

To verify the NRCs contractor performs final status surveys (FSS) in the Unit 2 and 3

intake structures, in accordance with the approved project-specific plan, to ensure that

the licensees decommissioning activities and survey program in these areas have been

implemented in a manner that provides confidence in the results that the site does not

pose an undue risk to public health and safety.

3.2

Observations and Findings

a.

Review of Remedial Action Support Survey Program

The licensee and its decommissioning contractor plan to survey and release the Units 2

and 3 intake structures for backfilling. At the time of the inspection, the licensee had not

submitted its License Termination Plan which would include the proposed release

8

criteria for the intake structure surfaces. Although the License Termination Plan has not

been submitted, the contractor had developed proposed release criteria and submitted

the proposed criteria to the NRC for review and acceptance. The contractor also

developed procedures for remedial action support surveys (RASS). Although the

contractor was conducting some of the work at risk, without an approved License

Termination Plan, the NRC compared the contractors efforts against the guidance

provided in NUREG-1575, Multi-Agency Radiation Survey and Site Investigation

Manual (MARSSIM), and NUREG-1757, Consolidated Decommissioning Guidance,

volumes 1-3, which provide instructions for development of survey plans and

methodologies.

The inspectors reviewed the performance of the RASS in the Units 2 and 3 intake

structures. Procedures, chain of custody, survey data collection, data management,

survey quality assurance requirements, and records retention requirements were

inspected. A selection of RASS survey data with a focus on risk significance was

reviewed for compliance and adequacy by the inspectors. The contractors radiological

engineers were interviewed as to the methodology and execution of RASS surveys as

well as to explain select survey results reviewed by the inspectors.

The inspectors observed survey performance and interviewed select technicians

performing RASS surveys in a Class 2 survey unit in the Unit 2 intake structure. All

instruments in use were calibrated, used in accordance with procedures, and were of the

appropriate type to measure the radionuclides of concern. Instruments in use included

the Ludlum 2350-1 with 44-10, 43-68, and 43-37 detectors as appropriate to the

radionuclides of concern. All technicians observed by the inspectors were appropriately

trained for the instruments they were operating, and their training was verified current.

In summary, the contractor designed and conducted RASS surveys in accordance with

procedural requirements and with NRC guidance documents.

b.

Review of Final Status Surveys

When the reactors were in operation, the underground intake structures provided cooling

water to the turbine condensers and provided dilution for effluent releases. Both Unit 2

and Unit 3 have separate intake structures that are mirror images of each other. Due to

the small footprint of the owner-controlled area, the licensee needs to release the intake

structures for unrestricted use and to backfill the structures to support future

decommissioning of the remainder of the radioactive contaminated power block.

To support the release and survey of the intake structures, the licensees

decommissioning contractor removed the sludge-type sediment and scraped and power-

washed the surfaces in both intake structures. Following cleaning, the contractor plans

to conduct, or has conducted, RASS and FSS as needed to support the release of the

structures.

Once the FSS results indicate the intake structures meet the unconditional release

criteria specified in site procedures, the licensee plans to backfill the intake structures

with a flowable concrete fill from the -26 feet (-26) to the 7 elevation in both intake

structures. The backfilled area will remain in place after license termination.

9

To dewater the Unit 2 intake structure, a grout bag was permanently placed on the

return side to isolate the Pacific Ocean from the structure while accommodating

continued use of the saltwater dilution pumps. Two gates were installed in the Unit 2

intake side to isolate the remaining Unit 2 area. The Unit 3 side was isolated from the

Pacific Ocean by installing a stop gate on the return side and 2 gates on the intake side.

The licensee determined the boundary of intake structure survey units as the concrete

that extends from the 7 elevation down to -26, and structures that accommodated gates

4 and 6. The historical site assessment and initial sampling results found contaminants

to only be in the sediments which if present, would only be in the floor areas where the

sediments had settled. A potential area of interest is the outfall vent shaft area between

the outfall weir and gate 1, where the radwaste effluent lines entered and discharged

into the outfalls of both units. Sediments/seafoam around the Unit 2 vent shaft at the 30

level has also shown prior contamination. With the sediments removed, no individual

measurement is expected to exceed the contractors proposed estimated derived

concentration guideline level (eDCGL). Thus, the -13 and the -26 floor surfaces and

conjoined wall surfaces up to 1 meter for both units was classified as a Class 2 survey

Unit, along with the area between the outfall weir and gate 1 to the ceiling. The

remaining areas were classified as Class 3 survey units as these areas were not

expected to contain any residual activity. Due to the size of the areas to be surveyed, the

licensee determined that a minimum of two Class 2 survey units and one Class 3 survey

unit will be required for each intake structure.

Using the guidance provided in MARSSIM, the licensee determined that a minimum of

14 systematic sample locations are required for each Class 2 survey unit, and 14

random sample locations are required for each Class 3 survey unit. Sample locations

were plotted on a map of the intake structures and then clearly marked on the areas

inside the intake structures. For each sample location, a concrete sample was collected,

a wipe sample is taken, and a static beta/gamma measurement is taken.

The licensee used scan measurements to identify if any small areas of elevated

radioactivity were present. In the Class 2 survey units, scanning surveys were designed

to detect small areas of elevated activity that were not detected by measurements using

the systematic pattern. For the Class 3 survey units, judgmental surface scans were

performed on areas with the highest potential for residual contamination based on

professional judgement. The licensees survey plan required a minimum of 25% scan

surveys of Class 2 survey units, and a minimum of 10% scan surveys in the Class 3

survey units. Scans were conducted using the in-situ object counting system, followed

by direct beta measurements and smears. The licensee had sufficient field

instrumentation, which were appropriately calibrated, available to perform the necessary

scan surveys.

In addition, concrete samples, obtained by core drilling, were collected at all systematic

and random sample locations. Concrete samples were sent off-site to a third-party

laboratory for volumetric analysis. Samples were collected and processed in accordance

with procedures SDS-LT1-PCD-1005, Sample Media Collection for Site

Characterization and Final Status Survey, and SDS-LT1-PCD-1006, Sample Media

Preparation for Site Characterization and Final Status Survey.

The licenses survey plan identified an investigational process where elevated areas are

identified and investigated. This included any areas identified by the surveyor during

10

real-time scanning and any surface concrete sample exceeding the sum of fractions,

using the eDCGLs. Quality control scans and samples were performed on 10% of the

sample locations in each survey unit. The target minimum detectable concentration for

laboratory analysis of samples was between 10%-50% of the radionuclides eDCGL.

In summary, the inspectors concluded that the licensee had developed and implemented

a FSS program that was generally consistent with NRC guidance.

c.

Verification and Confirmatory Surveys

Per MARSSIM, a confirmatory survey is used to provide data to substantiate the results

of the licensees final status survey. Confirmatory survey activities are limited in scope to

spot-checking conditions at selected locations, comparing findings with those of the final

status survey, and performing independent statistical evaluations of the data developed

from the confirmatory survey with the final status survey. The goal is to conduct a

sufficient survey so that the NRC can conclude that the licensees FSS program was

implemented in a manner that provides confidence in the licensees results.

The inspectors observed the NRCs contractor, Oak Ridge Associated Universities, Oak

Ridge Institute for Science and Education (ORISE), conducted confirmatory surveys in

the two intake structures. The implementation of the confirmatory surveys will assist the

NRC with the assessment of the licensees FSS design, implementation, and results for

demonstrating compliance with the release criteria for the intake structures. The staff

from ORISE used an NRC-approved specific project plan for the confirmatory surveys.

Surface scans were conducted for gamma radiation using a Ludlum model 44-10 sodium

iodide scintillation detector. Alpha/beta surface scans were conducted using a Ludlum

model 43-37 gas-flow proportional counter. Confirmatory scan density was 100% scan

coverage on the floors and lower 1 meter of walls. Two volumetric core samples were

collected from the Unit 2 discharge area upper walls and one volumetric sample taken

from the west wall in Unit 3, areas identified by ORISE as having elevated alpha-plus-

beta results. The results of the core samples will be communicated to the licensee under

separate correspondence.

3.3

Conclusion

The licensees contractor designed and conducted RASS surveys in accordance with

procedural requirements and with NRC guidance documents. The inspectors concluded

that the licensee had developed and implemented a FSS program that was generally

consistent with NRC guidance. A contractor conducted confirmatory surveys on behalf of

the NRC. The results of the confirmatory survey will be presented to the licensee under

separate correspondence.

4

Exit Meeting Summary

On January 26, 2023, the inspectors presented the final inspection results to the Chief

Nuclear Officer and Vice President Decommissioning and other members of the

licensees staff. The inspectors asked the licensee whether any materials examined

during the inspection should be considered proprietary. No proprietary information was

identified except for certain SDS procedures and documents which were marked as

proprietary.

Attachment

SUPPLEMENTAL INSPECTION INFORMATION

KEY POINTS OF CONTACT

Licensee and Contractor Personnel

A. Bates, SCE, Regulatory Affairs Manager

D. Bauder, SCE, Chief Nuclear Officer and Vice President Decommissioning

V. Bilovsky, SCE, Decommissioning Project Director

J. Carey, SCE, Corrective Action Program Manager

R. Corbett, SDS, Radiation Protection Manager

J. Janke, SCE, ISFSI Manager

R. Kalman, SDS, Executive Sponsor

C. Ladd, San Diego Gas & Electric

J. Madigan, SCE, Nuclear Oversight and Safety Culture Manager

S. Mannon, SDS, Regulatory Affairs Manager

M. Morgan, SCE, Licensing Engineer

R. Quam, SCE, Security Manager

R. Pontes, SCE, Environmental/Waste & Radiation Protection General Manager

L. Rafner, SCE, Regulatory Affairs

D. Randall, SDS, LT/FSS Manager

S. Scholler, SDS, LT/FSS Project Manager

S. Sewell, SCE, Radiation Protection and Waste Manager

INSPECTION PROCEDURES USED

IP 71801

Decommissioning Performance and Status Review at Permanently Shutdown

Reactors

IP 86750

Solid Radioactive Waste Management and Transportation of Radioactive

Materials

IP 83801

Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Discussed

None

Closed

None

2

LIST OF ACRONYMS

ADAMS

Agencywide Documents Access and Management System

CFR

Code of Federal Regulations

eDCGL

estimated derived concentration guideline level

FSS

final status survey

GTCC

greater-than-Class C

ISFSI

Independent Spent Fuel Storage Installation

MARSSIM

Multi-Agency Radiation Survey and Site Investigation Manual

NRC

Nuclear Regulatory Commission

PSDAR

Post Shutdown Decommissioning Activities Report

RASS

remedial action support survey

SDS

SONGS Decommissioning Solutions

SFP

spent fuel pool

SONGS

San Onofre Nuclear Generating Station