ML23046A379
ML23046A379 | |
Person / Time | |
---|---|
Site: | San Onofre ![]() |
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
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
SUNSI Review
By: RJE
ADAMS:
Yes
No
Sensitive
Non-Sensitive
Non-Publicly Available
Publicly Available
Keyword
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.
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
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
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
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
Decommissioning Performance and Status Review at Permanently Shutdown
Reactors
Solid Radioactive Waste Management and Transportation of Radioactive
Materials
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
Agencywide Documents Access and Management System
CFR
Code of Federal Regulations
eDCGL
estimated derived concentration guideline level
final status survey
greater-than-Class C
Independent Spent Fuel Storage Installation
MARSSIM
Multi-Agency Radiation Survey and Site Investigation Manual
NRC
Nuclear Regulatory Commission
Post Shutdown Decommissioning Activities Report
RASS
remedial action support survey
SONGS Decommissioning Solutions
spent fuel pool
San Onofre Nuclear Generating Station