IR 05000206/2007018

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IR 05000206-07-018; on 11/27/2007 - 11/30/2007; Southern California Edison Co., San Onofre Nuclear Generating Station; Unit 1. Decommissioning Report. No Violations
ML080600306
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 02/29/2008
From: Whitten J
Division of Nuclear Materials Safety IV
To: Rosenblum R
Southern California Edison Co
References
IR-07-018
Download: ML080600306 (19)


Text

ary 29, 2008

SUBJECT:

NRC INSPECTION REPORT 050-00206/07-018

Dear Mr. Rosenblum:

This refers to the inspection conducted on November 27-30, 2007, at Southern California Edison Companys San Onofre Nuclear Generating Station, Unit 1 facility. This inspection was an examination of decommissioning 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. The inspection included an examination of selected procedures and representative records, observations of activities, and interviews with personnel.

A preliminary exit briefing was presented to your staff at the conclusion of the onsite inspection.

Following the receipt of confirmatory survey sample results, a final briefing was presented telephonically to members of your staff on February 1, 2008. The enclosed report presents the results of the confirmatory survey and the overall results of the inspection. In summary, the inspection determined that you were conducting decommissioning activities in compliance with regulatory and license requirements.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Should you have any questions concerning this inspection, please contact the undersigned at (817) 860-8197 or Mr. Robert Evans, Senior Health Physicist, at (817) 860-8234.

Sincerely,

/RA/

Jack E. Whitten, Chief Nuclear Materials Safety Branch B

Southern California Edison Co. -2-Docket No.: 050-00206 License No.: DPR-13

Enclosure:

NRC Inspection Report 050-00206/07-018 (w/Attachments 1 & 2)

REGION IV==

Docket No: 050-00206 License No: DPR-13 Report No: 050-00206/07-018 Licensee: Southern California Edison Co.

P.O. Box 128 San Clemente, California 92674 Facility: San Onofre Nuclear Generating Station, Unit 1 Location: San Clemente, California Dates: November 27-30, 2007 Inspectors: Robert J. Evans, PE, CHP, Senior Health Physicist Nuclear Materials Safety Branch B Janine F. Katanic, PhD, Health Physicist Nuclear Materials Safety Branch B Accompanied By: James C. Shepherd, Senior Project Manager Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs Chris A. McKenney, Senior Systems Performance Analyst Environmental Protection & Performance Assessment Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs Approved By: Jack E. Whitten, Chief Nuclear Materials Safety Branch B Attachments: Confirmatory Survey Sample Results Supplemental Inspection Information ADAMS Entry: IR05000206-07-018 on 11/27/2007 - 11/30/2007; Southern California Edison Co., San Onofre Nuclear Generating Station; Unit 1. Decommissioning Report. No VIOs.

Enclosure

EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Unit 1 NRC Inspection Report 050-00206/07-018 This inspection was a routine, announced inspection of decommissioning activities being conducted at the San Onofre Nuclear Generating Station (SONGS), Unit 1 facility. In summary, the licensee was conducting decommissioning activities in compliance with regulatory and license requirements.

Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors

  • The licensees safety review and design change program was in compliance with 10 CFR 50.59 requirements (Section 1).

Self Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors

  • The licensee conducted self-assessments and audits in accordance with Quality Assurance program requirements (Section 2).

Decommissioning Performance and Status Review at Permanently Shutdown Reactors

  • The licensee conducted demolition work with an emphasis on industrial and radiological safety. Radiation protection controls had been implemented including postings, boundaries, and labels inside the Unit 1 industrial area. The licensee was conducting subsurface dewatering activities in a controlled manner, and the liquid effluent was being monitored for radioactivity prior to release (Section 3).
  • The licensee conducted radiological surveys in the Independent Spent Fuel Storage Installation (ISFSI) pad construction zone, but past surveys had not considered the presence of workers in the area. The licensee agreed to perform a radiation dose evaluation for workers constructing the new ISFSI pad (Section 3).

Inspection of Final Surveys at Permanently Shutdown Reactors

  • The licensee was conducting final surveys in accordance with site procedure requirements. The licensee had significantly improved its ability to correlate radiological surveys with the established coordinate system in the Unit 1 industrial area. In response to NRC questions, the licensee elected to clarify the intent of a procedure requirement for independent assessments of final status survey records, to expand and document its justification for taking background measurements from known or potentially impacted areas, and to develop a guideline, job performance standard, or similar document to facilitate consistency in survey documentation (Section 4).
  • The inspectors conducted a confirmatory survey in the area of the former containment building foundation. Licensed radioactive materials were not identified in concentrations that were greater than the NRCs generic screening criteria (Section 4).

-2- Enclosure

Solid Radioactive Waste Management and Transportation of Radioactive Materials

  • The licensee was conducting radioactive waste shipments in accordance with site procedures and regulatory requirements (Section 5).

-3- Enclosure

Report Details Summary of Plant Status San Onofre Nuclear Generating Station, Unit 1 was permanently shut down during November 1992 and was permanently defueled by March 1993. The unit remained in SAFSTOR until June 1999 when decommissioning was initiated. At the time of this inspection, the licensee was conducting decommissioning activities under the DECON option as stated in its Post Shutdown Decommissioning Activities Report dated December 15, 1998. DECON is defined as the immediate removal and disposal of all radioactivity in excess of levels which would permit the release of the facility for unrestricted use.

Site activities completed since the previous inspection included the demolition of the remaining portions of the sphere enclosure building wall, the removal of the containment and the spent fuel building foundations, and the slurrying of the void spaces in the circulating water pit. Work in progress during the inspection included demolition of the remaining portions of the radwaste building walls, excavation of potentially contaminated rubble and soil, backfilling and compaction of the excavated areas, packaging of low level radioactive waste, and shipment of these packaged wastes to an out-of-state disposal site.

1 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (37801)

1.1 Inspection Scope The inspectors conducted reviews of the licensees design change process to ensure compliance with the requirements of 10 CFR 50.59.

1.2 Observations and Findings Regulation 10 CFR 50.59 addresses the change control process, a process used by the licensee to determine if proposed changes to the facility, procedures, tests, or experiments are subject to a license amendment and NRC approval. The control process was implemented through site procedure SO123-XV-44, "10 CFR 50.59 and 72.48 Program." This procedure provided instructions for both initial screening and subsequent full evaluation, if necessary, of facility or procedure changes to confirm if the licensee could implement proposed changes without prior NRC approval.

The inspectors reviewed selected engineering change packages for Unit 1 activities.

The inspectors determined that none of the change packages reviewed required prior NRC approval. Packages were found to be technically adequate and contained sufficient justification for the proposed change.

1.3 Conclusions The licensees safety review and design change program was in compliance with 10 CFR 50.59 requirements.

-4- Enclosure

2 Self Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors (40801)

2.1 Inspection Scope The inspectors evaluated the effectiveness of the licensee in identifying, resolving, and preventing issues that degrade safety or the quality of decommissioning.

2.2 Observations and Findings The licensee conducted several different types of audits and self-assessments to ensure compliance with regulatory requirements and license conditions. The self-assessments included quality assurance (QA) audits, QA surveillances, and leadership observations.

The inspectors reviewed selected QA audits, surveillances, and leadership observations involving Unit 1, and the inspectors conducted site tours and interviewed QA auditors.

Routine QA audits are required to be conducted to ensure compliance with regulatory requirements and license conditions. The audit program is described in Section 17.2.18.2 of the QA Program Topical Report SCE-1-A. This section also specifies the program areas to be audited and the frequency for conducting the audits. To ensure that audits were completed in a timely fashion, the licensee maintained a schedule of the proposed dates for the audits. For calender year (CY) 2007, the inspectors determined that the required audits had been completed, were currently in progress, or were scheduled by the licensee to be completed in a timely manner.

The inspectors reviewed five audits that had been conducted during CY 2007 by the licensees staff. The audits included operational controls, environmental monitoring, radiation protection, fire protection, and technical specifications compliance audits. The five audits were determined to be comprehensive in scope. No audit findings were identified by the licensees staff involving the Unit 1 decommissioning project.

In addition to the performance of audits, the licensee created a Unit 1 Site Radiological Characterization Plan/Quality Assurance Project Plan. The licensee created this QA plan to establish the quality requirements for the Unit 1 Comprehensive Ground Records Program. The inspectors noted that the implementation of the new QA plan would be beneficial to the licensee for ensuring the quality of future final radiological surveys.

The inspectors reviewed the QA surveillances of the final status survey activities, including one surveillance conducted during late-October 2007. During this surveillance, the auditor concluded that the final status survey program had demonstrated improvement since the previous review, including the documentation of survey results.

One weakness was identified by the auditor involving the documentation of survey meter calibration efficiencies. An Action Request was issued by the licensee to formulate corrective actions for this self-identified issue.

The licensee used leadership observations to provide direct oversight of decommissioning activities. The leadership observation program was a method which ensured third-party and management oversight of decommissioning work in progress.

-5- Enclosure

According to the licensee, leadership observation data is one of many tools used for early identification of potentially unsafe behavior trends. The inspectors reviewed selected leadership observations for Unit 1 transportation and final status survey activities. The inspectors concluded that leadership observations helped the licensee ensure that field activities were being conducted in a timely and safe manner.

2.3 Conclusions The licensee conducted self-assessments and audits in accordance with QA program requirements.

3 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (71801)

3.1 Inspection Scope The inspectors evaluated whether the licensee and its contracted workforce were conducting decommissioning activities in accordance with license and regulatory requirements.

3.2 Observations and Findings During site tours, the inspectors observed decommissioning activities in progress. The work included demolition of the former radwaste building wall and movement and handling of radioactive material. Industrial safety and radiation protection controls were evident in these activities. Safety representatives were continuously present during work activities. The inspectors concluded that radiological controls in place at the time of the inspection for these activities met regulatory requirements.

The licensee continued to conduct dewatering operations to support subsurface excavations below the groundwater table. At the time of the inspection, the licensee was operating five dewatering pumps. The discharge of these five pumps was being routed to the north industrial area yard sump.

The licensee continued to sample the dewatering well discharge fluid at least weekly.

The water samples obtained by the licensee were analyzed for total gamma activity and tritium concentrations. The inspectors reviewed the sample results for CY 2007. The analyses for water samples collected in CY 2007, with the exception of two samples, did not identify any radioactivity in concentrations greater than the minimum detectable concentrations (MDC) of the sampling equipment. Two water samples exceeded the MDCs of the sampling equipment. The samples were collected from dewatering well No. 6 during mid-October 2007, and each sample contained tritium in concentrations just above the detection limit of the measurement equipment. Well No. 6 is located immediately west of the former containment building. The two water samples contained tritium in concentrations of less than 3 picocuries per liter. Although the shallow groundwater in the vicinity of the Unit 1 site is not considered as drinking water, these two water sample results were well below the 20,000 picocuries per liter limit specified by the U.S. Environmental Protection Agency for tritium in drinking water.

-6- Enclosure

During the inspection, the licensee was in the process of constructing a second ISFSI concrete pad. Iron workers were installing rebar for the second pad. Since these construction activities were being conducted within the Unit 1 industrial area, the inspectors elected to conduct a radiological survey of the work area.

The inspectors performed ambient gamma exposure surveys of the work area using a Ludlum Model 19 microRoentgen meter (NRC No. 015546, Serial No. 33532, calibrated to radium-226, calibration due date of 02/12/08). The survey results across the construction area varied from 20 R/hr to 200 R/hr with a background of 15 R/hr.

The variation in ambient gamma exposure rates was a result, in part, of proximity to the loaded ISFSI modules.

The inspectors noted that the workers in the pad construction area were not wearing personnel dosimeters, in part, because the area was not considered a radiologically controlled area by the licensee. However, at the time of the inspection, an evaluation had not been performed by the licensee to determine if radiological conditions in the area of the ISFSI modules would required personnel monitoring. The health physics staff indicated they had performed general area surveys, but these surveys did not consider whether individuals might be routinely occupying the area on a continuous basis. The inspectors also noted that the ISFSI fence had been recently moved closer to the existing ISFSI modules in order to accommodate the construction of the new ISFSI pad. This new arrangement placed construction workers in areas that would not normally have been occupied. To address the questions raised by the inspectors, the licensee elected to develop Individual Task Assignment 07-039 to perform a radiation dose evaluation for workers constructing the new ISFSI pad. The inspectors plan to review this dose evaluation during a future inspection.

The inspectors examined the radiological postings and signs affixed to the loaded ISFSI modules. The inspectors noted that several radiological postings had fallen from some of the ISFSI modules, and other postings were discolored, damaged, or illegible. The inspectors reported these observations to the licensees health physics staff. In response, the licensee immediately generated Action Request 071101540 to document the problem and to formulate corrective actions. Prior to the conclusion of the onsite inspection, all of the radiological postings that had fallen off the ISFSI modules were re-affixed to the modules using silicon. Additionally, the postings that were discolored/damaged were replaced. The licensee also outlined to the inspectors its plan to conduct routine inspections of the integrity of the radiological postings on the ISFSI modules.

3.3 Conclusions The licensee conducted demolition work with an emphasis on industrial and radiological safety. Radiation protection controls had been implemented including postings, boundaries, and labels inside the Unit 1 industrial area. The licensee was conducting subsurface dewatering activities in a controlled manner, and the liquid effluent was being monitored for radioactivity prior to release.

-7- Enclosure

The licensee conducted radiological surveys in the ISFSI pad construction zone, but past surveys had not considered the presence of workers in the area. The licensee agreed to perform a complete radiation dose evaluation for workers constructing the new ISFSI pad.

4 Inspection of Final Surveys at Permanently Shutdown Reactors (83801)

4.1 Inspection Scope The inspectors verified that radiological measurements, surveys, and related documentation were being conducted by the licensee in accordance with site procedures and NRC guidance documents.

4.2 Observations and Findings a. Review of Decommissioning Survey Records During a previous inspection, the NRC inspectors questioned the licensees methodology for correlating radiological survey data to site location. In response, the licensee developed Action Request 070800078-2 to develop a comprehensive method for correlating radiological data with Engineering Drawing U1-C-0037, SONGS 1 Engineering Ground Plot. During the current inspection, the inspectors reviewed the actions taken by the licensee in response to the subject Action Request. The inspectors reviewed a sampling of electronic and hard-copy documentation for recent radiological surveys and found that the survey data could easily be correlated with the established site coordinate system.

The NRC also reviewed the licensees implementation of a procedure requirement for independent assessments. Section 6.5.4, Independent Assessment, of site procedure SO1-XXVIII-6.2.5, Comprehensive Ground Record Program for SONGS 1 Decommissioning Project, states, in part, that the licensee will obtain independent assessments of applicable decommissioning radiological characterization documents by knowledgeable industry experts. Section 6.5.4 further notes that the reviews will focus primarily on the consistency of documents with guidance such as NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), Revision 1.

Finally, Section 6.5.4 notes that the results of the independent assessment will be recorded.

The intent of this procedure was discussed with licensee personnel. Licensee personnel stated that they believed they were meeting the intent of the requirements in the procedure. As various stages of the Unit 1 decommissioning project were completed, the results have been recorded in record books. These record books were prepared by the Unit 1 health physics staff, reviewed by other licensee personnel, and reviewed by an industry expert from the SONGS licensing staff. The NRC inspectors were not able to determine the depth and scope of the independent assessment provided by the industry expert from the licensees licensing staff. Other than a signature, the results of the independent review were not documented in the record books. As a result of the NRCs observations, the licensee elected to generate Action Request 071200378-02 to-8- Enclosure

clarify the intent of Section 6.5.4 as it applies to independent assessment by an industry expert, scope of review, and requirements for documentation.

The inspectors also discussed the nomenclature and terminology used in site procedure SO1-XXVIII-6.2.5, Comprehensive Ground Record Program for SONGS 1 Decommissioning Project, with the licensees staff. The licensees staff acknowledged that changes were needed to clarify the procedure wording. As a result these discussions, the licensee generated Action Request 071200378-01 to review the site procedure for consistency in terminology.

During two prior NRC inspections, documented in NRC Inspection Report 050-00206/05-012 dated November 22, 2005 (ADAMS ML053260484), and NRC Inspection Report 050-00206/07-014 dated August 21, 2007 (ADAMS ML072350164),

the inspectors identified the licensees apparent departure from MARSSIM guidance regarding use of background reference areas. In particular, the inspectors noted that, in several situations, background measurements were obtained from within the survey units being surveyed. The first time this matter was discussed with the licensee, Action Request 051100014 was generated to review the method used by the licensee to conduct background surveys. The Action Request subsequently documented the licensees effort to defend how background measurements were being conducted in several specific areas. During a subsequent inspection, the inspectors noted that the licensee had continued the practice of conducting background measurements within other known or potentially impacted areas. The inspectors questioned the licensees previous justification for departing from MARSSIM guidance, and as a result, the licensee generated Action Request 070800078-1 to review and address background data collection methods and the required documentation necessary to support background data for MARSSIM surveys.

During this inspection, the inspectors again discussed the background measurement issue with members of the licensees staff. Because the licensee continued to obtain background measurements from within the survey units being surveyed, and because the licensees previous justifications appeared to be incomplete, the inspectors discussed the need for appropriate and defensible background measurements with the licensee. As a result of these additional discussions, the licensee opened a third Action Request, No. 071101458, to further address its methods for determining and defending background measurements taken within the survey unit being surveyed.

The inspectors also reviewed an entry from the licensees leadership observation program related to MARSSIM surveys. In this particular observation, an individual observed a health physics technician documenting a MARSSIM survey and recording the results as less than Minimum Detectable Concentration (MDC). The leadership observer coached the technician to record the calculated activity concentration. The observer noted that the survey was then documented correctly. The inspectors discussed this issue with licensee personnel who indicated that there were no standard instructions or guidelines for the documentation of MARSSIM surveys, including how to record the survey results. As a result, the licensee generated Action Request 071200378-03 to develop a guideline, job performance standard, or similar document to facilitate consistency in MARSSIM survey documentation.

-9- Enclosure

b. Conduct of NRC Confirmatory Survey The inspectors conducted a confirmatory survey in the north industrial area, specifically, in the vicinity of the former containment foundation. This area had been excavated by the licensee and was scheduled to be backfilled with clean material. The confirmatory survey consisted of measurements of concrete contamination levels, measurements of ambient gamma radiation levels, and the collection of two soil samples. In summary, licensed radioactive material was not identified during the confirmatory survey in concentrations greater than the NRCs generic screening criteria suggesting that the licensee had effectively remediated the area.

The concrete surface surveys were conducted using an Eberline E-600 survey meter (NRC No. 079977, Serial No. 2463, calibration due date of 09/25/08) coupled to an SHP-380AB alpha-beta probe. The ambient gamma exposure rates were measured using a Ludlum Model 19 microRoentgen meter (NRC No. 015546, Serial No. 33532, calibration due date of 02/12/08, calibrated to radium-226). Prior to conducting the confirmatory surveys, the inspectors collected background measurements in the north industrial area and calculated a MDC for the survey meter.

The inspectors collected 34 measurements of alpha and beta contamination on concrete. The measurement results are provided in Table 1 of Attachment 1 to this inspection report. Only one beta particulate measurement exceeded the MDC of the survey meter. This survey measurement, a net count of 103 cpm above the average background level, was compared to the NRCs generic screening criteria provided in NUREG-1757, Volume 1, Revision 2, Consolidated Decommissioning Guidance, Table B.1, Acceptable License Termination Screening Values of Common Radionuclides for Building-Surface Contamination. The survey measurement was compared to the most limiting screening level: 7,100 dpm/100 cm2 for cobalt-60. Based on the efficiency of the survey meter, the survey measurement of 103 cpm corresponds to a surface contamination value of 1,355 dpm/100 cm2, a measurement which was below the screening level. In summary, all concrete surface contamination measurements were below the NRCs generic screening values.

Ambient gamma radiation levels were measured in the area of the former containment foundation. With a background of 15 R/hr, the measurements ranged from 12-23 R/hr. Several isolated deposits of clay-like soils exhibited slightly elevated exposure rates, up to 45 R/hr. However, the licensee had previously identified these clay-like soils and had determined that these soils contained small amounts of naturally occurring radioactive material. The NRC has not established regulatory acceptance criteria for outdoor ambient gamma exposure rates.

The inspectors collected two soil samples for offsite analysis. The samples were collected in areas that exhibited slightly elevated exposure rates (above background).

The samples were submitted to Oak Ridge Institute for Science and Education (ORISE)

for analysis. The sample results are presented in Table 2 of Attachment 1 to this inspection report. In summary, no licensed radioactive material above background levels was identified in the two samples.

-10- Enclosure

4.3 Conclusions The licensee was conducting final surveys in accordance with site procedure requirements. The licensee had significantly improved its ability to correlate radiological surveys with the established coordinate system in the Unit 1 industrial area. In response to NRC questions, the licensee elected to clarify the intent of a procedure requirement for independent assessments of final status survey records, to expand and document its justification for taking background measurements from known or potentially impacted areas, and to develop a guideline, job performance standard, or similar document to facilitate consistency in survey documentation.

The inspectors conducted a confirmatory survey in the area of the former containment building foundation. Licensed radioactive materials were not identified in concentrations that were greater than the NRCs generic screening criteria.

5 Solid Radioactive Waste Management and Transportation of Radioactive Material (86750)

5.1 Inspection Scope The inspectors reviewed the licensees activities to properly process, package, store, and ship radioactive wastes. Inspectors also reviewed transportation activities being conducted by the licensee to ensure compliance with applicable NRC and U.S. Department of Transportation (DOT) regulations.

5.2 Observations and Findings During the inspection, the Unit 1 staff shipped three high-sided gondola cars via rail to an out-of-state disposal site. The gondola cars contained low specific activity (LSA-I)

concrete rubble from Unit 1 that was placed into lift liners. The inspectors reviewed selected shipment documentation including bills of lading, radioactive waste manifests, emergency response information, final radiation survey data, removable radiological contamination data, radionuclide analyses, and railcar/gondola visual inspection information. The selected documentation reviewed by the inspectors was found to be in compliance with licensee procedures and had appropriate supervisory reviews.

The inspectors performed walk-downs of the gondola cars to verify markings, placarding, and the visual condition of the gondola cars. In addition, the inspectors performed confirmatory surveys of the four sides and undercarriage of the loaded gondola cars. Confirmatory surveys performed by the inspectors for the four sides and undercarriage of each of the gondola cars agreed with the licensees final radiation survey data for the shipment.

Also during the inspection, the Unit 1 staff shipped radioactive material in a DOT Type A package to an offsite analytical laboratory via air cargo through a common carrier. The shipment consisted of a five gallon steel drum that contained four samples in sealed poly bags. The samples were taken from the interior of various Unit 1 pipes. The inspectors reviewed selected documentation including the bill of lading, shippers-11- Enclosure

declaration of dangerous goods, emergency response information, final radiation survey data, removable radiological contamination data, radionuclide analyses for each of the four samples, and photographs of the labeled shipping container. The documentation was found to be in compliance with DOT regulations and licensee procedures.

The inspectors reviewed five audits of the radioactive waste transportation program that were conducted under the licensees leadership observation program during the year prior to the inspection. The purpose of three of the audits was to review documentation for shipments of low-level radioactive waste and verify adherence to DOT regulatory requirements, licensee procedures, and other disposal-related requirements. The other two audits reviewed activities in progress. One audit captured observations related to the delivery of rail cars into the Unit 1 industrial area, and the second audit captured observations related to the loading of lift liner bags into gondola cars. In summary, the audits of the radioactive waste transportation program, conducted under the licensees leadership observation program, appeared to be effective in identifying program strengths and weaknesses.

5.3 Conclusions The licensee was conducting radioactive waste shipments in accordance with site procedures and regulatory requirements.

6 Exit Meeting Summary The inspectors presented the preliminary inspection results to members of licensee management at the exit meeting on November 30, 2007. Following the receipt of the soil sample results, a final exit briefing was held telephonically with the licensee on February 1, 2008. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.

-12- Enclosure

ATTACHMENT 1 Table 1 Total Radiological Contamination on Concrete in North Industrial Area a Alpha Beta Location counts per minute (cpm) counts per minute (cpm)

1 9 297 2 11 298 3 5 301 4 6 330 5 7 276 6 7 290 7 7 310 8 4 326 9 7 304 10 9 298 11 8 309 12 6 266 13 6 393 14 4 321 15 6 307 16 8 318 17 7 288 18 4 308 19 4 269 20 4 304 21 11 247 22 2 275 23 8 312 24 4 297 25 5 263 26 8 301 27 2 293 28 6 273 Attachment 1

Table 1 Total Radiological Contamination on Concrete in North Industrial Area a Alpha Beta Location counts per minute (cpm) counts per minute (cpm)

29 1 311 30 5 296 31 4 283 32 7 263 33 6 293 34 6 291 Average 6 305 a.

Results were not corrected for background or efficiency. The average background was 6 cpm for alpha contamination and 290 cpm for beta contamination. The calculated minimum detectable concentration for the instrument was 20.4 cpm for alpha contamination and 372 cpm for beta contamination.

Table 2 Soil Sample Results from Gamma Spectroscopy Sample Description ORISEs Sample Results and Location picocuries per gram (pCi/g)

NRC-1SO cobalt-60 0.00 +/- 0.02 Grid 133 Northeast Wall cesium-137 0.01 +/- 0.01 NRC-2SO cobalt-60 0.00 +/- 0.03 Grid 113 North Wall cesium-137 0.00 +/- 0.02-2- Attachment 1

ATTACHMENT 2 PARTIAL LIST OF PERSONS CONTACTED Licensee T. Clepper, Decommissioning Manager R. Corbett, Manager, Health Physics M. Crumes, Supervisor, Health Physics D. Dick, Supervisor, Chemistry S. Enright, Project Manager, Unit 1 Health Physics S. Jones, Health Physics Engineer R. Hanson, Nuclear Oversight & Assessment B. Katz, Vice President L. Kelly, Engineer, Nuclear Regulatory Affairs D. Pilmer, Project Manager, Nuclear Regulatory Affairs J. Reilly, Vice President A. Scherer, Manager, Nuclear Regulatory Affairs M. Short, Manager, Nuclear Oversight D. Todd, Nuclear Oversight & Assessment C. Williams, Compliance Manager INSPECTION PROCEDURES USED IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 40801 Self Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 83801 Inspection of Final Surveys at Permanently Shutdown Reactors IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED AND CLOSED Opened None Closed None Discussed None Attachment 2

LIST OF ACRONYMS AND ABBREVIATIONS CFR Code of Federal Regulations cpm counts per minute DOT U.S. Department of Transportation ISFSI Independent Spent Fuel Storage Installation IP Inspection Procedure LSA low specific activity MDC minimum detectable concentration MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual (NUREG-1575)

ORISE Oak Ridge Institute for Science and Education QA quality assurance SONGS San Onofre Nuclear Generating Station-2- Attachment 2