ML25045A210
| ML25045A210 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/26/2025 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Bailly F Southern California Edison Co |
| Evans R | |
| References | |
| IR 2025001 | |
| Download: ML25045A210 (1) | |
See also: IR 05000361/2025001
Text
February 26, 2025
Frederic Bailly, Vice President
and Chief Nuclear Officer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION
REPORT 050-00361/2025-001; 050-00362/2025-001 AND NOTICE OF
VIOLATION
Dear Frederic Bailly:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted
onsite from January 27-30, 2025, for San Onofre Nuclear Generating Station, Units 2 and 3.
The inspectors discussed the preliminary inspection results with you and members of your staff
at the end of the onsite inspection on January 30, 2025. The final inspection results were
presented to you via Microsoft Teams meeting on February 11, 2025. The inspection results are
documented in the enclosures to this letter.
This inspection examined activities conducted under your license as they relate to public health
and safety, the common defense and security, and to confirm compliance with the
Commissions rules and regulations and with the conditions of your licenses. Within these
areas, the inspection consisted of selected examination of procedures and representative
records, observation of activities, independent measurement of radiation levels, and interviews
with personnel. Specifically, the inspectors reviewed decommissioning performance; remedial
and final surveys; safety reviews, design changes, and modifications; and solid radioactive
waste management and transportation of radioactive materials.
The enclosed report discusses a Severity Level IV violation related to the licensees failure to
implement the fire protection program as required by 10 CFR 50.48(f)(1). This violation was
evaluated in accordance with the NRC Enforcement Policy, which can be found on the NRC
website at http://www.nrc.gov/aboutnrc/regulatory/enforcement/enforce-pol.html. The violation is
cited in Enclosure 1, Notice of Violation (Notice), and the circumstances surrounding it are
described in detail in the subject inspection report (Enclosure 2). The NRC determined that this
violation did not meet the criteria to be treated as a non-cited violation (NCV) because the issue
was not entered into a credited corrective action program and the corrective actions taken were
not adequate, consistent with Section 2.3.2 of the NRC Enforcement Policy.
F. Bailly
2
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice. The NRC
review of your response to the Notice will also determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a
copy of this letter, its enclosures, and your response will be made available electronically for
public inspection in the NRC Public Document Room or from the NRCs Agencywide
Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs
Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response
should not include any personal privacy or proprietary information so that it can be made
available to the public without redaction.
If you have any questions regarding this inspection report, please contact Eric McManus at
817-200-1127 or the undersigned at 817-200-1249.
Sincerely,
Jeffrey E. Josey, Chief
Decommissioning, ISFSI, Operating Reactor Branch
Division of Radiological Safety and Security
Docket Nos. 50-361; 50-362
Enclosures:
2. Inspection Report 050-00361/2025-001; 050-00362/2025-001
w/Attachment: Supplemental Inspection Information
Distribution via ListServ
Signed by Josey, Jeffrey
on 02/26/25
F. Bailly
3
SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-
00361/2025-001; 050-00362/2025-001 AND NOTICE OF VIOLATION - DATED
FEBRUARY 26, 2025
DISTRIBUTION:
JMonninger, ORA
JLara, ORA
JGroom, DRSS
NOKeefe, DRSS
RAlexander, ORA
DCylkowski, ORA
VDricks, ORA
TSmith, ORA
AAlen-Arias, OEDO/ETA
SAnderson, NMSS/DUWP/RDB
ASnyder, NMSS/DUWP/RDB
LWilkins, OCA
AMoreno, RIV/OCA
R4-DRSS-DIOR-DECOM
DOCUMENT NAME: SAN ONOFRE NUCLEAR GENERATING STATION - NRC INSPECTION REPORT 050-
00361/2025-001; 050-00362/2025-001 AND NOTICE OF VIOLATION
ADAMS Accession Number: ML25045A210
SUNSI Review By:
RJE
ADAMS:
Yes
No
Sensitive
Non-Sensitive
Non-Publicly Available
Publicly Available
Keyword NRC-002
OFFICE
SHP:DIOR:DRSS
HP:DIOR:DRSS
SHP:DIOR:DRSS
C:DIOR:DRSS
NAME
REvans
EMcManus
SAnderson
JJosey
SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE
02/14/25
02/14/25
02/24/25
02/26/25
OFFICIAL RECORD COPY
Enclosure 1
Southern California Edison Company
Docket Nos. 50-361; 50-362
San Onofre Nuclear Generating Station
San Clemente, CA
During an NRC inspection conducted on January 27-30, 2025, a violation, with three examples,
of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the
violation is listed below:
Title 10 CFR 50.48(f) states in part that the licensee shall maintain a fire protection
program to address the potential for fires that could cause the release or spread of
radioactive materials.
Licensee fire protection implementing procedure SDS-FP1-PGM-0015, Control of
Ignition Sources, revision 13, states in part:
1.
Section 4.1.7: Licensee must verify all Class A combustibles or Dry Active Waste
bags within 35 feet of hot work have been removed or are shielded with approved
welding curtains, welding blankets or welding pads.
2.
Section 4.1.9: Licensee must relocate combustibles a minimum of 5 feet from the
side opposite work performed on metal walls.
Contrary to the above, the licensee failed to maintain the require standoff distance
between ignition sources and combustible materials, as evidenced by the following three
examples:
1.
On December 4, 2024, the licensee failed to maintain the 5 feet distance when they
were welding a metal shield to a shipping container containing dry active waste
which resulted in the burning of the waste material in the container.
2.
On January 20, 2025, the licensee failed to maintain 5 feet distance when they were
welding a shield to a shipping container containing dry active waste which again
resulted in burning of the waste material in the container.
3.
On February 6, 2025, the licensee failed to verify all combustible material within 35
feet of hot work was removed prior to the start of hot work which resulted in sparks
from cutting contacting flammable material.
This is a Severity Level IV violation (Section 6.3 d.3).
Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby
required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the
Regional Administrator, Region IV, within 30 days of the date of the letter transmitting this
Notice of Violation. This reply should be clearly marked as a "Reply to a Notice of Violation, and
should include for each violation: (1) The reason for the violation, or, if contested, the basis for
disputing the violation or severity level; (2) The corrective steps that have been taken and the
results achieved; (3) The corrective steps that will be taken; and (4) The date when full
compliance will be achieved. Your response may reference or include previous docketed
2
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or a Demand for
Information may be issued requiring information as to why the license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken. Where
good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Your response will be made available electronically for public inspection in the NRC Public
Document Room or in the NRCs Agencywide Documents Access and Management 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. If
personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request withholding of such material, you must specifically identify the portions of your response
that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,
explain why the disclosure of information will create an unwarranted invasion of personal
privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information). If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described
in 10 CFR 73.21.
Dated this 26TH day of February 2025
Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.
050-00361; 050-00362
License Nos.
Report Nos.
050-00361/2025-001; 050-00362/2025-001
Licensee:
Southern California Edison Company
Facility:
San Onofre Nuclear Generating Station, Units 2 and 3
Location:
5000 South Pacific Coast Highway
San Clemente, California
Inspection Dates:
Onsite January 27-30, 2025
Exit Date:
February 11, 2025
Inspectors:
Robert J. Evans, PE, CHP, PhD, Senior Health Physicist
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Eric S. McManus, Health Physicist
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Accompanied by:
Tiffany N. Rushing, Health Physicist
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Approved By:
Jeffrey E. Josey, Chief
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Attachment:
Supplemental Inspection Information
2
EXECUTIVE SUMMARY
San Onofre Nuclear Generating Station
NRC Inspection Report 050-00361/2025-001; 050-00362/2025-001
This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced
inspection of decommissioning activities being conducted at the San Onofre Nuclear Generating
Station. In summary, the licensee and its decommissioning general contractor were found to be
conducting activities in accordance with site procedures, license requirements, and applicable
NRC regulations, with one exception as described below.
Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors
The licensee was effectively implementing decommissioning activities at Units 2 and 3 in
accordance with approved procedures and commitments provided in the PSDAR. The
licensee maintained good radiological control over these work activities. (Section 1.2)
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors
The licensee implemented final status survey isolation and control measures in accordance
with approved procedures. The licensee continued to identify, document, and resolve
problems in the final status survey program area. (Section 2.2)
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
The licensee developed and implemented a written program for safety reviews, design
changes, and modifications. The program was being implemented by qualified individuals.
Based on a limited NRC review of recently issued safety reviews, the licensee was noted to
be effectively implementing the program. (Section 3.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials
The inspectors reviewed selected radioactive waste management and transportation
activities and identified one violation of regulatory requirements. The violation involved the
licensees failure to maintain a fire protection program to address the potential for fires that
could cause the release or spread of radioactive materials. (Section 4.2)
3
Report Details
Summary of Plant Status
Southern California Edison Company (SCE), the licensee, formally notified the NRC in June
2013 that it had permanently ceased power operations at San Onofre Nuclear Generating
Station (SONGS), Units 2 and 3 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML131640201). The NRC subsequently issued the permanently
defueled technical specifications in July 2015 (ML15139A390), along with revised facility
operating licenses to reflect the permanent cessation of operations at Units 2 and 3.
As required by Title 10 to the Code of Federal Regulations (10 CFR) 50.82(a)(4), the licensee
submitted its Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC on
September 23, 2014 (ML14269A033). The PSDAR outlined the licensees planned
decommissioning activities. The current version of the PSDAR is dated May 7, 2020
(ML20136A339). As discussed in the revised PSDAR, the licensee chose the decommissioning
alternative DECON. DECON is the removal or decontamination of equipment, structures, or
portions of the facility and site that contain radioactive contaminants to levels that permit
termination of the license.
On December 20, 2016, the licensee announced the selection of AECOM and Energy Solutions
as the decommissioning general contractor. The joint venture between the two companies was
named SONGS Decommissioning Solutions (SDS). The SDS organization manages most of the
decommissioning activities as described in the PSDAR.
During the inspection, the licensee was preparing the rigging equipment for the Unit 3 reactor
vessel lift and subsequent segmentation of the vessel shell. In Unit 2, the licensee removed the
final reactor coolant pump and prepared it for shipment to a disposal site. The material handling
facility was operational for open air demolition of the site radioactive structures.
1
Decommissioning Performance and Status Review at Permanently Shutdown
Reactors (Inspection Procedure [IP] 71801)
1.1
Inspection Scope
The inspectors observed site activities, reviewed documents, and interviewed site
personnel in order to: (1) evaluate the status of decommissioning and verify whether the
licensee was conducting decommissioning and maintenance activities in accordance with
regulatory and license requirements; (2) evaluate the licensee awareness of work activities
to assess their control and conduct of decommissioning; and (3) evaluate the licensees
decommissioning staffing, personnel qualifications, and training requirements, including
that of the contracted workforce, to ensure that license requirements were met, as
applicable to the current decommissioning status.
1.2
Observations and Findings
a.
Status of Decommissioning
At the time of the onsite inspection, the licensee and its decommissioning general
contractor SDS were conducting major decommissioning activities in accordance with
the commitments provided in Section II.B.1 of the PSDAR. The inspectors discussed the
4
current decommissioning schedule with management staff, observed daily planning
meetings, and observed open air demolition work in progress. The status of
decommissioning was noted to be commensurate with the challenges encountered.
During the onsite inspection, the Units 2 and 3 radwaste buildings were being
demolished. The building demolition work was approximately 90-percent complete.
The inspectors attended meetings that included discussion of decommissioning activities
as well as the current plant status for each day. The topics discussed included an As
Low As Is Reasonably Achievable (ALARA) briefing, safety briefing, current work
projects, and near-term work projects. The meeting provided participants with current
information of the work in progress including radiological and industrial safety updates as
needed.
The inspectors performed tours of the Unit 2 and Unit 3 containment buildings, facilities
adjacent to the containment buildings, and the former location of the multipurpose
handling facility in the south yard area. Plant staff appeared to be knowledgeable of site
conditions and based on observations, the inspectors determined that the licensee was
adequately maintaining the material condition of the facilities, as well as the structures,
systems, and components that are necessary for safe decommissioning. The inspectors
identified good housekeeping practices and appropriate radiological postings and
labeling. The inspectors did not identify any radiological areas that were not adequately
identified and posted by the licensee.
The inspectors conducted site tours, in part, to observe open air demolition activities.
The work was being conducted in accordance with the instructions provided in SDS-
RP1-TSD-24-01, Open-Air Demolition Plan for San Onofre, revision 2, The licensee
was demolishing the buildings, sorting the debris, transferring the debris to the adjacent
material handling facility, and loading the debris into railcars for offsite disposal.
The inspectors reviewed the radiological status of the open-air demolition project. The
radiological work control requirements were provided in Radiation Work Permit 25-0-77,
revision 0. The permit included worker requirements for dosimetry, protective clothing,
and respiratory protection. The inspectors reviewed the actual and budgeted dose
estimates for the demolition workers for 2025. At the time of the inspection, the
combined assigned doses to demolition workers were about 38 millirem with an annual
budgeted dose of 495 millirem. In summary, the licensee continued to monitor demolition
workers for exposure to radiation and radioactive material, and actual doses were
consistent with the estimated doses for the project.
The open-air demolition plan also provides instructions for daily environmental air
sampling, workplace air sampling, contamination surveys, and dose rate surveys. The
inspectors reviewed the results for the January 28, 2025, daily sampling, in part, to
determine if contamination was spreading outside of the demolition work area. The daily
results did not identify surface contamination outside of the work area, and relatively low
exposure rate readings were identified inside the work area. The licensee continued to
conduct daily sampling as required by the open-air demolition plan, and the daily results
indicated no release of contamination outside of the work area during the inspection.
5
b.
Observation of Decommissioning Work Activities in Units 2 and 3 Containments
The inspectors toured the Units 2 and 3 containments to observe work in progress and
to independently assess radiological conditions. In Unit 2, the licensee continued to
prepare for future reactor segmentation activities including the cutting of the vessel
nozzles. The licensee completed the cutting and removal of the two steam generators.
The licensee removed the final reactor coolant pump from the containment building
during the inspection. The other three reactor coolant pumps were still onsite, awaiting
packaging and offsite shipment for disposal.
In Unit 3, the major work activities included continued preparation for future cutting of the
reactor vessel shell. The licensee continued to cut and remove the remainder of the
steam generators from the containment building. All four reactor coolant pumps had
been removed from containment and shipped offsite for disposal.
The inspectors observed strong radiation protection support in both containments.
Housekeeping was adequate based on the work in progress. A minor radioactive
labeling issue was identified and reported to the radiation protection staff for resolution.
The inspectors conducted independent radiological surveys during site tours using a
Thermo Scientific Radeye G survey meter (serial number 13420, calibration due date of
7/23/2025, calibrated to cesium-137). Overall, the measured exposure rates were
consistent with existing signs, boundaries, and postings.
The licensee and its decommissioning contractor were conducting decommissioning
activities in accordance with the instructions provided in site procedures and
commitments provided in the PSDAR.
c.
Decommissioning Staffing and Training
As described in Section 3.2 below, the inspectors conducted a review of the training and
qualification program for personnel conducting 10 CFR 50.59 safety reviews, design
changes, and modifications. In summary, the training was conducted in accordance with
procedure requirements, and all reviewers were found to be trained and qualified to
conduct their assigned reviews.
1.3
Conclusions
The licensee was effectively implementing decommissioning activities at Units 2 and 3 in
accordance with approved procedures and commitments provided in the PSDAR. The
licensee maintained good radiological control over these work activities.
2
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors
(IP 83801)
2.1
Inspection Scope
The inspectors observed site activities, reviewed documents, and interviewed site
personnel to verify that permanently shut down power reactor sites have been
decontaminated to acceptable residual radioactivity levels and to verify that the
licensees procedures, radiological measurements, decommissioning surveys, and
6
documentation of decommissioning surveys were implemented in accordance with NRC
guidance.
2.2
Observations and Findings
a.
Remediation Activities and Final Status Surveys
Section II of the PSDAR states that appropriate radiological and environmental programs
will be maintained throughout the decommissioning process to ensure radiological safety
of the workforce and the public, and environmental compliance is maintained. The
inspectors reviewed selected areas of the licensees final status survey and radiological
assessment programs to ensure that surveys were being conducted in accordance with
procedural requirements. Specifically, the inspectors reviewed the licensees
implementation of its final status survey isolation and control measures.
The isolation and control measures are described in procedure SDS-LT1-PCD-1008,
Final Status Survey Isolation and Control Measures, revision 2, isolation and control
measures are used to limit the potential for cross-contamination from other
decommissioning activities and to maintain the final configuration of the applicable
survey units. These measures are implemented for survey units that are ready for final
status surveys and survey units that have been final status surveyed. The measures
include access control to the survey units, installation of postings and boundaries, and
post-survey surveillances.
At the time of the inspection, the areas that were under isolation and control included the
Unit 3 intake gate No. 1, former makeup demineralizer area, former multipurpose
handling facility area, electrical tunnels, and tendon galleries. Other previously surveyed
areas included the underground intake and discharge tunnels that were previously
backfilled with a flowable fill material and are no longer accessible.
The inspectors conducted site tours, in part, to observe the accessible areas being
managed with isolation and control measures. All areas were properly posted with signs
and boundaries. The inspectors also reviewed the licensees program for managing the
post-turnover surveillances. The licensee had established and implemented a program
consistent with procedure requirements. All surveillances were found to be up-to-date.
No evidence of cross-contamination had been identified by the licensee in any final
status survey unit at the time of the inspection.
b.
Verification and Confirmatory Surveys
The inspectors did not conduct independent confirmatory or verification surveys during
this inspection.
c.
Problem Identification and Resolution
The inspectors reviewed recent corrective action program entries involving final status
surveys. The decommissioning contractor was writing Condition Reports (CR) to
address problems as they were identified. Recent issues that were documented in CRs
included a missed meter response background check and clarification of training
requirements. For all CRs, the licensee developed and implemented corrective actions
to prevent reoccurrence of the identified problems.
7
2.3
Conclusions
The licensee implemented final status survey isolation and control measures in
accordance with approved procedures. The licensee continued to identify, document,
and resolve problems in the final status survey program area.
3
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown
Reactors (IP 37801)
3.1
Inspection Scope
The inspectors reviewed documents and interviewed site personnel to verify that the
licensees safety review process was being implemented in accordance with the
requirements of 10 CFR 50.59, Changes, Tests, and Experiments. The inspectors
reviewed the licensees implementation of its safety review programs, selected design
changes and completed safety reviews, training and qualification of reviewers, and SDS
CRs issued in this program area.
3.2
Observations and Findings
a.
Safety Reviews, Design Changes, and Modifications
The licensees programs are described in procedures ENG-3, 10 CFR 50.59, 72.48,
and 50.82 Program, revision 1, and SDS-RA1-PGM-0002, 10 CFR 50.59 and 72.48
Program, revision 3. The inspectors reviewed recently issued safety reviews, design
changes, and modifications. These reviews included:
Elimination of the exclusion area boundary and clarification of site boundary due to
the absence of off-site design-basis accident consequences
Installation of protective enclosures over the lower beach discharge flap valves to
prevent rocks and cobble from obstructing valve operation during rainstorms
Abandonment of the onsite sewage treatment plant and oily waste holding sumps,
and to remove the components from the defueled safety analysis report
Modify, mobilize, and relocate the liquid radioactive waste system from plant
equipment to a mobile platform to allow for demolition of the radwaste building
Verification of the tornado missile protection requirements for tank T-351 to allow the
tank to be used for temporary storage of radioactive water
The inspectors noted that the reviews were conducted and documented by trained and
qualified individuals. No findings of significance were identified during the NRC review of
these safety reviews.
b.
Training and Qualification Program Review
Procedure ENG-3, 10 CFR 50.59, 72.48, and 50.82 Program, revision 1, Section 5.4
provided the qualification requirements for SCE staff, while procedure SDS-RA1-PGM-
0002, 10 CFR 50.59 and 72.48 Program, revision 3, Section 3.2.2, Attachment 5.1 and
Attachment 5.2 provided the training requirements for SDS staff. The inspectors
reviewed both training programs and discussed the programs with representatives from
8
each organization. Both programs had a sufficient number of qualified individuals to
implement the respective programs, and the qualifications were consistent with
procedure requirements.
c.
Problem Identification and Resolution
There were no recent SCE Action Request (AR) or contractor CRs of significance issued
in this program area.
3.3
Conclusions
The licensee developed and implemented a written program for safety reviews, design
changes, and modifications. The program was being implemented by qualified
individuals. Based on a limited NRC review of recently issued safety reviews, the
licensee was noted to be effectively implementing the program.
4
Solid Radioactive Waste Management and Transportation of Radioactive Materials
(IP 86750)
4.1
Inspection Scope
The inspectors observed site activities, reviewed documents, and interviewed site
personnel to verify the effectiveness of the licensees programs for transportation of
radioactive materials. The focus of the inspection was on recently issued CRs
documented for events related to the preparation and transportation of radioactive
material.
4.2
Observations and Findings
a.
Hot work adjacent to combustibles
The inspectors reviewed two contractor CRs (the contractors corrective action program
is not a credited corrective action program) generated after hot work had caused the
burning of Dry Active Waste (DAW). After the on-site inspection was completed, the
inspectors reviewed one licensee AR generated after it was determined that hot work
was again being performed contrary to procedural requirements. Based on the results of
this review, the NRC inspectors identified one violation, with three examples, of NRC
requirements.
Title 10 CFR 50.48(f) requires the licensee to maintain a fire protection program to
address the potential for fires that could cause the release or spread of radioactive
materials. The licensees fire protection program implementing procedure SDS-FP1-
PGM-0015, Control of Ignition Sources, revision 13, states in part:
1.
Section 4.1.7: Licensee must verify all Class A combustibles or Dry Active Waste
bags within 35 feet of hot work have been removed or are shielded with approved
welding curtains, welding blankets or welding pads.
2.
Section 4.1.9: Licensee must relocate combustibles a minimum of 5 feet from the
side opposite work performed on metal walls.
9
Contrary to the above, the licensee failed to maintain the require standoff distance
between ignition sources and combustible materials, as evidenced by the following three
examples:
1.
Contrary to the section 4.1.9 above, on December 4, 2024, the licensee failed to
maintain a 5-foot distance between hot metal surfaces and combustible materials
which resulted in the burning of combustible materials. Specifically, the licensee
contractors were welding shielding to a shipping container which contained DAW.
Contrary to licensee procedures, the DAW was not located greater than 5 feet from
the hot area of the container. The heat from the welding burned the DAW. There
were no flames observed, and the heat was extinguished immediately by the fire
watch. CR SDS-002042 provided the following corrective actions: (a) examination of
container contents prior to performing welding on containers; and (b) providing
shielding on the interior of a container if the container includes flammable material.
2.
Contrary to the section 4.1.9 above, on January 20, 2025, the licensee failed to
maintain a 5-foot distance between hot metal surfaces and combustible materials
which resulted in the burning of combustible materials. Specifically, the licensee
contractors were welding shielding to a shipping container which contained DAW.
The DAW was located greater than 5 feet from the hot areas of the container,
however, during the welding, the DAW shifted into the hot area and the heat from the
welding burned the DAW. There were no flames observed, and the heat was
extinguished immediately by the fire watch. This event was documented in CR SDS-
002057.
3.
Contrary to section 4.1.7 above, on February 6, 2025, the licensee failed to verify all
Class A combustibles within 35 feet of hot work were removed or shielded with
approved welding curtains, welding blankets or welding pad prior to the start of hot
work. Specifically, combustible material was located approximately 10 feet from
active torch cut work performed by a contractor. This resulted in sparks from the
torch cut contacting the flammable material. An SCE observer identified the
deficiency, and the combustibles were moved to an area greater than 35 feet away
from the hot work. No fire or resulted from this event. This event was documented in
AR 0225-70419.
Based on the continued events, the inspectors determined that the corrective actions
taken were not adequate. On January 30, 2024, SCE issued AR 0125-77465 which
states that the licensee will track action taken by the contractor to improve performance
related to hot work as well as to track corrective action creation and implementation.
After the third hot work procedure violation on February 6, 2025, SCE issued a stop work
order for all hot work activities while the above events and appropriate corrective actions
are evaluated. (VIO 050-00362/2025-01-01; Failure to verify all combustibles had been
removed when performing hot work)
b. Leaking Railcars
The inspectors reviewed CR SDS-002048 generated after two railcars containing
radioactive material were found leaking liquid from the bottom of the container after they
were certified for shipment. Upon identification of the leaks, the containers were not
permitted to leave the site. The containers were loaded with concrete and metal from
building demolition. The licensee conducted radiation and contamination surveys and
10
verified no radioactive material had leaked out of the container. The licensee placed a
hold on shipments, inspected similar railcars on site, and subsequently identified
additional railcars with wet contents.
The inspectors reviews of documentation and interviews with personnel verified all
required actions were performed in accordance licensee emergency procedure SDS-
WM1-PCD-0003, Transportation Incident and Emergency Response Plan, revision 7.
The inspectors also verified the containers used for transport of the demolition debris
were in accordance with Department of Transportation requirements for shipment of
Limited Surface Activity material.
The inspectors observed corrective actions implemented after the leaking containers
were investigated. The corrective actions included changes to the debris collection and
increased oversight during loading to ensure liquid is minimized during loading of
demolition debris. The inspectors observations, interviews, and record reviews validated
the licensees corrective action program effectively identified and bounded the problem.
c.
Imbalanced Railcars
The inspectors reviewed CR SDS-002054 generated after two railcars carrying
radioactive material were stopped during transit by the rail company. The railcars transit
was suspended after a railyard found the railcars had imbalanced loads. The licensees
response was prompt, and they determined there were no radiological problems in
addition to the imbalanced load. During the investigation, the licensee determined the
railcar carrier caused the imbalance for both railcars. The licensee worked with the
appropriate Agreement State and obtained the required mobile license with authorized
personnel to correct the imbalance and allow the railcars to complete the shipment to the
waste disposal site. The inspectors interviews, and record reviews validated the
licensees corrective action program effectively assessed and responded the
transportation event.
4.3
Conclusions
The inspectors reviewed selected radioactive waste management and transportation
activities and identified one violation of regulatory requirements. The violation involved
the licensees failure to maintain a fire protection program to address the potential for
fires that could cause the release or spread of radioactive materials.
5
Exit Meeting Summary
The inspectors presented the preliminary inspection results to Frederic Bailly, Vice
President and Chief Nuclear Officer, and other members of the licensees staff at the
conclusion of the onsite inspection on January 30, 2025. A final exit briefing was
provided to the Vice President and Chief Nuclear Officer on February 11, 2025. The
inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified except for
certain SDS procedures and documents which were marked as proprietary.
Attachment
SUPPLEMENTAL INSPECTION INFORMATION
KEY POINTS OF CONTACT
Licensee and Contractor Personnel
N. Alchaar, Manager, Project Management Office
F. Bailly, SCE, Chief Nuclear Officer and Vice President Decommissioning
J. Carey, SCE, Corrective Action Program Manager
C. Cates, SCE, Manager, Prudency, Safety Culture and Employees Concern Program
G. Ferrigno, SDS, Radiation Protection Manager
T. Giard, SDS, D&D Project Director
R. Kalman, SDS, Executive Sponsor
T. Laursen, SDS, Corrective Action Program Manager
J. Madigan, SCE, Manager, Radiation Protection and Waste Oversight; Nuclear Oversight
S. Mannon, SDS, Programs Project Director/Regulatory Manager
A. Martinez, SDS, Performance Improvement Manager
M. Morgan, SCE, Manager, Regulatory Affairs
L. Mosher, SCE, Manager, Communications
J. Peattie, SCE, General Manager, Site Operations
R. Pontes, SCE, General Manager, Site Closure and Environmental Oversight
L. Rafner, SCE, Regulatory Affairs
S. Seward, Audit Services Representative
S. Sewell, SCE, Manager, Radiation Protection and Waste
B. Sholler, SDS, LT/FSS Project Manager
J. Stephenson, SCE, Manager, Engineering
INSPECTION PROCEDURES USED
Decommissioning Performance and Status Reviews at Permanently Shutdown
Reactors
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown
Reactors
Solid Radioactive Waste Management and Transportation of Radioactive
Materials
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000362/2025-01-01
Failure to verify all combustibles had been
removed when performing hot work
Closed
None
Discussed
None
2
PARTIAL LIST OF DOCUMENTS REVIEWED
Procedures
SDS-FP1-PGM-0015, Control of Ignition Sources, revision 13
SDS-RP1-TSD-24-01, Open-Air Demolition Plan for San Onofre, revision 2
SDS-LT1-PCD-1008, Final Status Survey Isolation and Control Measures, revision 2
ENG-3, 10 CFR 50.59, 72.48, and 50.82 Program, revision 1
SDS-RA1-PGM-0002, 10 CFR 50.59 and 72.48 Program, revision 3
SDS-WM1-PCD-0003, Transportation Incident and Emergency Response Plan, revision 7
SDS-3-M-CO-2212, U3 RV (RLS) Reactor Lifting System Equipment Installation, revision 0
SDS-LT1-PCD-1008, Final Status Survey Isolation and Control Measures, revision 2
SDS-RP1-PGM-3000, Control of Radioactive Material, revision 5
SDS-RP1-PCD-3005, Portable Ventilation and the Use of Vacuum Cleaners, revision 9
SDS-QA1-PGM-0001, SONGS DecommissioningSolutions Quality Assurance Program,
revision 5
Brandenburg MA0879-SONGS, Site-specific Health and Safety Plan, revision 12/30/2020
Condition Reports/Action Requests Reviewed
SDS CR SDS-002042, December 4, 2024, Heat transfer through Conex, from welding, to DAW
bag
SDS CR SDS-002057, January 20, 2025, Transfer of heat from welding to a DAW bag inside
ISO container
SDS CR SDS-002048, December 1, 2025, Two railcars identified to be leaking from the bottom
corners of floor
SDS CR SDS-002054, January 15, 2025, SONGS railcar placed on Bad Order by United
Pacific
Open Air Demo Nightly Report, January 28, 2025
SCE AR 1024-49410, October 10, 2024, Undesirable conditions related to safety signs
SCE AR 0225-70419, February 6, 2025, All combustibles not removed prior to performance of
hot work
Condition Reports/Action Requests Generated from Inspection
SCE AR 0125-77465, January 30, 2025, Track and document actions taken by the contractor to
improve performance specific to Hot Work
SDS CR SDS-002062, January 30, 2025, Evaluate monthly inventory frequency and labeling for
adequacy of in-service vacuums and HEPA ventilation units in accordance with SDS-RP1-PCD-
3005
Licensing Bases Documents
San Onofre Nuclear Generating Station Units 2 & 3 Defueled Safety Analysis Report (DSAR)
November 2024
Post-Shutdown Decommissioning Activities Report and Irradiated Fuel Management Plan dated
May 7, 2022
Miscellaneous
Radiation Work Permit 25-0-777
Signed Shipping Manifest LLRW-25-006, January 8, 2025
Signed Shipping Manifest LLRW-25-002, January 8, 2025
SONGS Hot Work Permit, January 20, 2025
SONGS Pre-Job Checklist/Post Job Brief, January 20, 2025
Calculation of Airborne Radioactivity Resulting from Smoldering Herculite, January 28, 2025
3
Open Air Demo Nightly Report dated January 28, 2025
SDS Daily ALARA Report dated January 29, 2025
Brandenburg Hot Work Permit MA0879, February 6, 2025
Safety Reviews, Design Changes, and Modifications
SCE Applicability Determination, Screens and/or Evaluations for Elimination of Exclusion Area
Boundary and Clarification of Site Boundary, 1220-99225-3, revision 0
SCE Engineering Change Package, NECP Number 1220-99225-4, Elimination of Exclusion
Area Boundary (EAB) and Clarification of Site Boundary, revision 0
SCE Applicability Determination, Screens, and/or Evaluations for Install Protective Enclosures
Over Beach Discharge Flaps, AR 1023-30925-6, revision 0
SCE Engineering Change Package, NECP Number 1023-30925-5, Install Protective Enclosures
Over Beach Discharge Flap Valves, revision 0
SDS Applicability Determination, SDS-50.59-2023-0009, Abandon Sewage Treatment Plant and
East/West Oily Waste Holding Sumps, revision N/A
SDS Design Plan, Sewage Treatment Plant Isolation, revision 0
SDS Applicability Determination, SDS-50.59-2022-0005, LRW Mobile Processing & Discharge,
revision 0
SDS Design Plan, LRW Mobile Processing & Discharge, revision 0
SONGS Calculation Package, SDS-EN1-CAL-0061m T-351 Tornado Missile Standard Review
Plan 3.5 Review, revision 1
LIST OF ACRONYMS
Agencywide Documents Access and Management System
As Low As Is Reasonably Achievable
Action Request
CFR
Code of Federal Regulations
CR
Condition Report
Dry Active Waste
Defueled Safety Analysis Report
IP
Inspection Procedure
Independent Spent Fuel Storage Installation
NRC
Nuclear Regulatory Commission
Post-Shutdown Decommissioning Activities Report
Southern California Edison Company
SONGS Decommissioning Solutions
San Onofre Nuclear Generating Station