ML25084A053
| ML25084A053 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/20/2025 |
| From: | Bailly F Southern California Edison Co |
| To: | NRC Region 4, Office of Nuclear Reactor Regulation |
| References | |
| IR 2025001 | |
| Download: ML25084A053 (1) | |
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An EDISON INTERNATIONAL'* Company U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 March 20, 2025
SUBJECT:
Docket Nos. 50-361 and 50-362 Frederic M. Bailly Vice President Decommissioning &
Chief Nuclear Officer San Onofre Nuclear Generating Station 10CFR2.201 Reply to a Notice of Violation, 2025-001, San Onofre Nuclear Generating Station (SONGS), Units 2 and 3
REFERENCE:
Letter from Mr. Jeffrey E. Josey (NRC) to Frederic M. Bailly (SCE) dated February 26, 2025,
Subject:
NRC Inspection Report 050-00361/2025-001 and 050-00362/2025-001, and Notice of Violation, (ADAMS Accession No. ML25045A210)
Dear Sir or Madam The referenced letter transmitted the results of NRC Inspection Report Nos.
050-00361/2025-001 and 050-00362/2025-001 to Southern California Edison (SCE). The inspection was conducted on-site from January 27, 2025, to January 31, 2025 for the San Onofre Nuclear Generating Station (SONGS). The inspection was a routine decommissioning inspection of SONGS. The referenced letter contained a Notice of Violation for a Severity Level IV violation of NRC requirements. Pursuant to 10 CFR 2.201, the Notice of Violation required SCE to provide a written reply within 30 days.
The Enclosure to this letter provides SCE's acceptance of and reply to the Notice of Violation provided in the referenced letter.
There are no new regulatory commitments in this letter or the Enclosure.
If you have any questions or require additional information, please contact me or Mr. Mark Morgan, at (949) 368-627 4.
Executed on ~~
/4 0 '; 2 o i S' Sincerely,
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Enclosure:
Reply to Notice of Violation 2025-001 cc:
J. Monninger, Regional Administrator, NRC Region IV A. Snyder, NRC Project Manager, SONGS Units 1, 2 and 3 and ISFSI
ENCLOSURE Reply to Notice of Violation 2025-001
Reply to Notice of Violation 2025-001 BACKGROUND AND EVENT
SUMMARY
San Onofre Nuclear Generating Station ceased operations in 2013. In 2020, active decommissioning of the site began and is expected to continue through 2028.
On December 4, 2025, SONGS was preparing a low-level radwaste container for shipment. A Hot Work Permit was approved by a qualified Permit Authorizing Individual (PAI). Shielding was being welded on the side of the container to ensure that dose rates were within those required by the Department of Transportation. During welding, the metal wall of the container heated up, causing a Dry Active Waste (DAW) bag containing rags, disposable protective clothing, and other slightly contaminated items located inside of the container to begin smoldering. No flames were observed, but the smoldering was identified by the fire watch on hand to monitor the activity and extinguished.
This incident was entered into a Corrective Action Program and screened as a Significance Level 3 issue for evaluation. Evaluation of the Condition Report included ensuring procedural requirements were met, including inspection of the inside of containers for combustibles prior to welding and moving the combustibles or providing shielding as necessary. These requirements were already in place prior to the time of the incident and no additional corrective actions were specified.
On January 20, 2025, during similar work, a DAW bag again began smoldering. The smoldering bag was again identified by the fire watch assigned to the task and extinguished.
Following both of these incidents, Radiation Protection personnel evaluated the area and there were no increased levels of contamination noted nor any exposure to personnel.
On February 6, 2025, during torch cutting of a hardened defense post from the side of a concrete tank enclosure, sparks were observed contacting combustible material that had been left within 10 feet from the source of the sparks. The Hot Work Permit for the torch cutting specified that combustible materials were to be removed at least 35 feet away from hot work.
Oversight personnel pointed out the discrepancy to workers, and combustible materials were moved out of the area.
Following the February 6, 2025 incident, SCE issued a stop work directive for all hot work on site. An Apparent Cause Evaluation was performed to determine causes and corrective actions to minimize the likelihood of recurrence of these issues. The scope of the cause evaluation includes the performance issues that led to the incidents described above and the failure of the Corrective Action Program to prevent recurrence following the initial incident.
The cause evaluation was approved on February 19, 2025 and accepted by SCE, and the stop work directive was lifted on February 20, 2025.
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DESCRIPTION OF VIOLATION 2025-001 Title 10 CFR 50.48(f) states in part that the licensee shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials.
Licensee fire protection implementing procedure SDS-FP1-PGM-0015, "Control of Ignition Sources," Revision 13, states in part:
- 1. Section 4.1.7: Licensee must "verify all Class "A" combustibles or Dry Active Waste bags within 35 feet of hot work have been removed or are shielded with approved welding curtains, welding blankets or welding pads."
- 2. Section 4.1.9: Licensee must "relocate combustibles a minimum of 5 feet from the side opposite work performed on metal walls."
Contrary to the above, the licensee failed to maintain the required standoff distance between ignition sources and combustible materials, as evidenced by the following three examples:
- 1. On December 4, 2024, the licensee failed to maintain the 5 feet distance when they were welding a metal shield to a shipping container containing dry active waste which resulted in the burning of the waste material in the container.
- 2. On January 20, 2025, the licensee failed to maintain 5 feet distance when they were welding a shield to a shipping container containing dry active waste which again resulted in burning of the waste material in the container.
- 3. On February 6, 2025, the licensee failed to verify all combustible material within 35 feet of hot work was removed prior to the start of hot work which resulted in sparks from cutting contacting flammable material.
SCE REPLY TO VIOLATION 2025-001
- 1. Reason for the Violation The Apparent Cause for these incidents was determined to be deficiencies in the implementation of hot work procedures. Workers did not take advantage of other methods of shielding allowed by the procedure. The supervisor assigned to the task was unfamiliar with the procedure and offered minimal guidance during the task, relying on the PAI to provide the oversight and guidance on that aspect of the work. The inspection of the container contents failed to identify the combustible material that was present, and as a result combustible material was not moved, no heat shielding was provided and a second fire watch was not required for the task as would otherwise have been required.
A Contributing Cause was determined to be that decisions on implementation of critical elements of the Fire Protection Program were inappropriately made at the worker level.
The decision that heat shielding would not be used was based in part upon cut-up steam generator tubing that was also in the container. Because this left inadequate clearance, 2
installation of heat shielding was considered to be impractical. This decision should have been elevated to a supervisory level at a minimum, particularly during the January 20 incident, given the focus on shielding of combustible container contents following the December 4 incident.
An additional Contributing Cause was determined to be inadequate significance screening of the initial incident in the Corrective Action Program. Specifically, the initial incident was screened as a Significance Level 3 incident. As a result, a more extensive evaluation of the incident was not required, nor were specifically prescribed corrective actions assigned or completed. In addition, review by a higher level of management (the Management Review Committee) was not required.
- 2. Corrective Actions Taken and Results Achieved SONGS has implemented several corrective actions to improve implementation of the Fire Protection Program requirements for hot work on site. These included: increased foreman and supervisor observations of hot work and other field activities; Project Director (or designee) review of the observations to assess hot work implementation; and enhanced training that included a Dynamic Learning Activity (DLA) for all selected PAis, fire watches and Decontamination and Dismantlement (D&D) supervisors. The DLA emphasized the hot work procedural requirements, applicable operating experience, and included a practical exercise to demonstrate competence.
To address the decision-making aspect of these issues, a supervisor or manager trained and qualified as a PAI is now required to sign off on all Hot Work Permits prior to initiating the activity to ensure the work can be performed safely and in accordance with the established requirements.
To address the aspect of problem identification and resolution of these issues, the screening criteria of the Corrective Action Program have been revised. Condition Reports that are related to select programs with regulatory impact will now automatically be screened at a higher significance level, that engages the Management Review Committee to determine the need for their review prior to closure of the CR. In addition, coaching has been provided to involved individuals and a lessons-learned memorandum has been provided to responsible managers highlighting the consequences of an ineffective evaluation to correct a deficiency.
- 3. Corrective Actions That Will Be Taken None.
- 4. Date When Full Compliance Will Be Achieved Full compliance was achieved on March 18, 2025, when the corrective actions described above were implemented.
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