ML16127A580

NRC Inspection Reports 05000361/2016001, 05000362/2016001 and 07200041/2016001

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

License Nos. NPF-10; NPF-15

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

License Nos. NPF-10; NPF-15

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)

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• 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,

-6-

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:

• Reactor Coolant System

• Emergency Core Cooling System

• 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

- 14 -

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

SONGS ODCM.

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

- 17 -

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

- 18 -

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

- 19 -

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.

- 20 -

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

• NECP 801314776, Transfer Load from MCC 2BF to MCC 2BW, 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.

- 21 -

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.

- 22 -

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

- 24 -

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

SONGS.

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

License Nos. NPF-10; NPF-15

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