ML062220655

IR 05000206-06-012, on 07/17-21/2006, SONGS, Unit 1

ML062220655
Person / Time
Site:	San Onofre
Issue date:	08/10/2006
From:	Spitzberg D NRC/RGN-IV/DNMS/FCDB
To:	Rosenblum R Southern California Edison Co
References
IR-06-012
Download: ML062220655 (14)

See also: IR 05000206/2006012

Text

August 10, 2006

Richard M. Rosenblum

Chief Nuclear Officer

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

SUBJECT: NRC INSPECTION REPORT 050-00206/06-012

Dear Mr. Rosenblum:

This refers to the inspection conducted on July 17-21, 2006, at Southern California Edison

Companys (SCE) San Onofre Nuclear Generating Station (SONGS), 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. The enclosed

report presents the results of that inspection. 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) 860-8191 or Mr. Emilio M. Garcia, Health Physicist, at (530) 756-3910.

Sincerely,

/RA/

D. Blair Spitzberg, Ph.D., Chief

Fuel Cycle and Decommissioning Branch

Docket No.: 050-00206

License No.: DPR-13

Enclosure: NRC Inspection Report

No.: 050-00206/06-012

Southern California Edison Co. -2-

cc w/enclosure:

Chairman, Board of Supervisors

County of San Diego

1600 Pacific Highway, Room 335

San Diego, CA 92101

Gary L. Nolff

Power Projects/Contracts Manager

Riverside Public Utilities

2911 Adams Street

Riverside, CA 92504

Eileen M. Teichert, Esq.

Supervising Deputy City Attorney

City of Riverside

3900 Main Street

Riverside, CA 92522

Ray W. Waldo

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

David Spath, Chief

Division of Drinking Water and

Environmental Management

California Department of Health Services

P.O. Box 942732

Sacramento, CA 94234-7320

Michael R. Olson

San Onofre Liaison

San Diego Gas & Electric Company

P.O. Box 1831

San Diego, CA 92112-4150

Ed Bailey, Chief

Radiologic Health Branch

State Department of Health Services

P.O. Box 997414 (MS 7610)

Sacramento, CA 95899-7414

Mayor

City of San Clemente

100 Avenida Presidio

San Clemente, CA 92672

Southern California Edison Co. -3-

James D. Boyd, Commissioner

California Energy Commission

1516 Ninth Street (MS 34)

Sacramento, CA 95814

Douglas K. Porter, Esq.

Southern California Edison Company

2244 Walnut Grove Avenue

Rosemead, CA 91770

James T. Reilly

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

Daniel P. Breig

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

A. Edward Scherer

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

Brian Katz

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

Southern California Edison Co. -4-

cc w/enclosure (via e-mail distribution):

LDWert

DBSpitzberg

HAFreeman

JCShepherd, NMSS/DWMEP/DD

CCOsterholtz, SRI

EMGarcia

RJEvans

KEGardin

FCDB File

SUNSI Review Completed: EMG ADAMS: O Yes G No Initials: EMG

O Publicly Available G Non-Publicly Available G Sensitive O Non-Sensitive

DOCUMENT NAME: s:\dnms\!fcdb\!emg2\6050206012.wpd final r:\_so1\2006

RIV:DNMS:FCDB C:FCDB

EMGarcia DBSpitzberg

/RA/ /RA/

08/10/06 08/10/06

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No: 050-00206

License No: DPR-13

Report No: 050-00206/06-012

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: July 17 - 21, 2006

Inspectors: Emilio Garcia, Health Physicist

Fuel Cycle & Decommissioning Branch

Approved and

Accompanied By: D. Blair Spitzberg, Ph.D., Chief

Fuel Cycle & Decommissioning Branch

Attachment: Supplemental Inspection Information

ADAMS Entry: IR05000206-06-012 on 07/17/2006 - 07/21/2006; Southern

California Edison Co., San Onofre Nuclear Generating Station;

Unit 1. Decommissioning Report. No VIOs.

-2-

EXECUTIVE SUMMARY

San Onofre Nuclear Generating Station, Unit 1

NRC Inspection Report 050-00206/06-012

This inspection was a routine, announced inspection of decommissioning activities being

conducted at San Onofre Nuclear Generating Station, Unit 1 facility. Areas inspected included

organization, management, and cost controls; safety reviews, design changes and

modifications; decommissioning performance and status review; and radioactive waste

treatment and environmental monitoring. The inspection determined that you were conducting

decommissioning activities in compliance with regulatory and license requirements.

Organization, Management, and Cost Controls at Permanently Shutdown Reactors

• The licensees organizational structure was consistent with the requirements of the

SONGS Unit 1 Technical Specifications. All managerial positions were staffed with

experienced individuals (Section 1.1).

• The licensees decommissioning funding status as reported in their Decommission

Funding Report was reviewed and found to meet applicable requirements. Based on

licensee projections of decommissioning costs and the amount of work completed at the

end of 2005, adequate funding would be available to complete Unit 1 decommissioning

(Section 1.2).

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 2).

Decommissioning Performance and Status Review at Permanently Shutdown Reactors

• The licensee was controlling the radiologically restricted area in accordance with

requirements. The licensee continued to make progress decommissioning the Unit 1

site (Section 3).

Radioactive Waste Treatment, and Effluent and Environmental Monitoring

• The licensees programs for monitoring radioactive liquid and gaseous effluent releases

and environmental monitoring were in compliance with license requirements. All

required samples had been collected, no sample result exceeded applicable limits, and

no adverse trends were identified (Section 4).

-3-

Report Details

Summary of Plant Status

San Onofre Nuclear Generating Station (SONGS), 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.

Work completed since the previous inspection included segmentation and removal of the spent

fuel pool liner and continued demolition of the concrete in containment.

1 Organization, Management, and Cost Controls at Permanently Shutdown

Reactors (36801)

1.1 Organization

a. Inspection Scope

The inspector reviewed the licensees organizational structure against the requirements

of the SONGS Unit 1 Technical Specifications, the De-fueled Safety Analysis Report

(DSAR) and the Topical Quality Assurance Manual (TQAM).

b. Observations and Findings

Section 6.2 of the Technical Specifications requires that the lines of authority,

responsibility and communications be established and defined for the highest

management levels through intermediate levels to include all organizations. The

Technical Specification also requires that a Southern California Edison Company (SCE)

Vice President shall be responsible for overall unit safety and that a SCE Vice President

shall have corporate responsibility for decommissioning activities.

The July 2006, amendment to the DSAR designated the Senior Vice President as the

Chief Nuclear Officer and to whom all levels of the organization report. Previously, this

position was designated as the Executive Vice-President. The Senior Vice-President

reports to the SCE Chief Executive Officer. The Vice-President Nuclear Generation had

ultimate responsibility for the safe operation of the three units. The Vice-President of

Engineering and Technical Services had responsibility for the decommissioning of

Unit 1. The DSAR further defined the lines of authority, responsibility and

communications through the intermediate levels of all onsite organizations. This

organization was consistent with that described in Chapter 1-B of the Topical Quality

Assurance Manual, with the exception that the title of Executive Vice-President had not

yet been revised to Senior Vice-President. The licensee maintained an updated

Organization Chart to reflect the individuals assigned to each position.

-4-

The incumbents to the positions of Senior Vice-President, Vice-President Nuclear

Generation, Vice-President of Engineering and Technical Services, Station Manager

and Manager, Unit 1 Decommissioning had been appointed to their positions since

December 2004, but all had many years of experience in the nuclear field and of service

with the licensee.

c. Conclusion

The licensees organizational structure was consistent with the requirements of the

SONGS Unit 1 Technical Specifications. All managerial positions were staffed with

experienced individuals.

1.2 Cost Controls

a. Inspection Scope

The inspector reviewed the licensees implementation of the requirements of

10 CFR 50.75(f)(1) regarding status of decommissioning funding.

b. Observations and Findings

10 CFR 50.75(f)(1) requires each power reactor licensee to submit a report on a 2-year

basis of (1) the amount of decommissioning funds estimated to be required for

decommissioning; (2) the amount accumulated to the end of the preceding calendar

year; (3) a schedule of annual amounts remaining to be collected; (4) the assumptions

used regarding the rates of escalation in decommissioning cost; (5) the rates of

earnings on decommissioning funds; (6) rates of other factors used in funding

projections; (7) any contracts upon which the licensee is relying pursuant to

10 CFR 50.75(e)(1)(v); (8) any modifications occurring to a licensees current method of

providing financial assurance; and (9) any material changes to trust agreements. This

regulation requires the biennial report to be submitted by March 31 of the reporting year.

The report covering the decommissioning fund status through calendar year 2005 was

submitted to the NRC on March 13, 2006. This timely report included information on the

nine items required in 10 CFR 50.75(f)(1).

c. Conclusion

The licensees decommissioning funding status as reported in their Decommission

Funding Report was reviewed and found to contain all information required by 10 CFR

50.75. Based on licensee projections of decommissioning costs and the amount of work

completed at the end of 2005, adequate funding would be available to complete Unit 1

decommissioning.

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

Reactors (37801)

-5-

2.1 Inspection Scope

The purpose of this portion of the inspection was to ascertain whether the licensee's

training program provides effective periodic training for personnel preparing, reviewing,

and approving safety evaluations.

2.2 Observations and Findings

Regulation 10 CFR 50.59 addresses the change control process, a process used by the

licensee to determine if a proposed change to the facility, procedures, tests, or

experiments is subject to a license amendment and NRC approval. The process is

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 can implement these changes without NRC approval. The program was a

common program for the two operating units and the decommissioning unit. The initial

screens and full evaluations are documented through the computerized Action Request

System. This computerized system checks to verify that the individual preparing,

reviewing and approving safety screens and full evaluations were current in their

training.

During the period of July 1, 2005 to July 17, 2006, no 10 CFR 50.59 safety evaluations

were conducted for Unit 1 activities and 35 safety screens were created or closed. The

inspector reviewed the training records and determined that all preparers and reviewers

were current with their training.

The inspector reviewed On-site Review Committee meeting minutes for the period of

June 1, 2005 to June 21, 2006. This committee had a standing agenda item to review

10 CFR 50.59 safety evaluations. The minutes indicated that no Unit 1 10 CFR 50.59

safety evaluations had been performed during this period. The minutes of the

February 15, 2006, meeting note that the Director, Unit 1 Decommissioning was no

longer a member of the Committee. This change was favored by the Director, Unit 1

Decommissioning and in view of the status of Unit 1 was acceptable.

2.3 Conclusions

The licensees safety review and design change program was in compliance with

10 CFR 50.59 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.

-6-

3.2 Observations and Findings

a. Site Tours/Control of Decommissioning Activities

The inspector conducted tours of the Unit 1 facility to observe radiological area postings

and boundaries. Access to the restricted and contaminated areas was controlled by

radiation caution signs, barricades, boundary lines, locked doors, and locked gates.

Radiological boundaries were well defined and postings were up-to-date in all areas.

The inspector conducted independent radiological surveys in the radiologically restricted

area using a Ludlum Model 2401-EC survey meter (NRC No. 21173G, calibration due

date 09/23/06). No abnormal radiological survey results were observed and all ambient

gamma exposure rate measurements were in agreement with posted radiation levels.

During this inspection, the licensee completed solidifying previously collected

radiologically contaminated water. The licensee intended to ship the resulting solid to

an offsite disposal site.

Removal of the steel spent fuel pool liner had been completed. The steel spent fuel

pool liner anchors imbedded in the concrete were being removed during this inspection.

Contaminated concrete surface in the spent fuel building was being scabbled to reduce

contamination to levels acceptable for open-air demolition.

Work was continuing with the demolition and removal of the concrete in containment. A

mechanical excavator had inadvertently pierced the steel containment resulting in flow

of water into the containment. The licensee concluded that the containment sphere

could become buoyant if it was not attached to the concrete base as originally

envisioned. The licensee had developed a plan to anchor the steel sphere to the

concrete base and to de-water the ground around the base to assure that the steel

sphere did not become buoyant. The location of some of the de-watering wells required

prior removal of the turbine building North extension. The turbine building North

extension was needed for the demolition of the upper portions of the spent fuel building.

The licensee had completed construction of the new yard sump and was preparing to

isolate the original intake and outfall canals. The eventual goal was to have these

structures released from the license. The licensee stated that they would keep NRC

informed of their schedule for sampling these structures.

The licensee had removed more than 46 percent (by weight) of the waste to be

removed.

3.3 Conclusions

The licensee was controlling the radiologically restricted area in accordance with

regulatory requirements. The licensee continued to make progress in decommissioning

of the Unit 1 site.

4 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)

-7-

4.1 Inspection Scope

The inspector reviewed the licensees program to control, monitor, and quantify releases

of radioactive materials to the environment in liquid, gaseous, and particulate forms.

4.2 Observations and Findings

a. Effluent Monitoring

Section D6.8.4.a of the Permanently Defueled Technical Specifications states that a

radioactive effluent control program shall be established, implemented, and maintained.

The methodology used to monitor, sample, and analyze the liquid and gaseous effluents

is provided in the Offsite Dose Calculation Manual (ODCM). The inspector compared

the program requirements specified in the ODCM to the sample results as documented

in the licensees 2005 Annual Radioactive Effluent Release Report (ARERR) dated April

24, 2006. This report was submitted on time and the licensee collected all samples

required by the ODCM. No sample result exceeded the applicable reporting level.

The report states that doses to an individual due to liquid effluents, airborne releases

and direct radiation were all a fraction of a millirem and well below the applicable limits.

The report notes that the ODCM was revised on February 25, 2005, with Revision 23.

This revision incorporated 1) removal of all the "notes" and applicable sections regarding

the completion of fuel transfer to the Independent Spent Fuel Storage Installation

(ISFSI), 2) addition of notes supporting the planned demolition of the liquid radwaste

treatment system, 3) updates related to the 2003-2004 Land Use Census, 4) corrected

dilution flow rate values, and 5) a minor change to a radiological environmental

monitoring program (REMP) sampling location. The report also notes that Liquid

Radwaste Treatment System (LRTS) was permanently removed from service on May

13, 2005. The sump pumps, piping and radiation monitoring system skid were removed

to support the demolition of the radwaste building.

The 2005 annual radioactive effluent release report also included solid waste shipment

information. During 2005, the licensee shipped solid wastes to disposal sites in Utah

and South Carolina, and to a volume reduction service in Utah. The licensee sent 85

shipments by rail and 153 shipments by truck. In addition, two shipments went to a

volume reduction contractor. The contractor subsequently shipped the compacted

wastes to the disposal site in Utah.

b. Environmental Monitoring

Section D6.8.4.b of the Permanently Defueled Technical Specifications states that a

radiological environmental monitoring program shall be established, implemented and

maintained. Program requirements are contained in the ODCM. The inspector

compared the ODCM requirements with the information provided in the licensees 2005

radiological environmental operating report dated April 24, 2006. The report Annual

Radiological Environmental Operating Report (AREOR) was applicable to all three

Units and ISFSI). This report was submitted on time and all ODCM required samples

had been obtained. No sample result exceeded the applicable regulatory limit.

-8-

Ambient radiation levels were measured at least 30 locations with calcium sulfate

(CaSO4) thermoluminescent dosimeters (TLDs). The environmental dosimeters were

exchanged quarterly. During 2005, the average routine indicator location dose was

17.19 millirem with a range of 10.13 to 29.32 millirem. The average control location

dose was 16.12 millirem with a range of 12.96 to 20.05 millirem. The report concluded

that statistically, the control and indicator doses were equivalent. The results suggests

that plant operation had a negligible effect on the ambient dose rates.

Air particulate samples were collected on a weekly basis from eight indicator locations

and from one control location. The samples were analyzed for gross beta activity, I-131,

and composited quarterly for gamma isotopic analysis. Per the requirements of ODCM,

the licensee evaluated the gross beta activity of the indicators to the control locations.

The indicator locations maximum gross beta activity in air in 2005 was 0.0791

picocuries per cubic meter and the 2004 control location average was 0.0245 picocuries

per cubic meter. No indicator location value exceeded ten times the annual average

gross beta activity of the control location data from the previous year. All iodine-131

sample results were below the lower limit of detection. Quarterly composite gamma

spectral analysis analyses identified only naturally occurring beryllium-7 (Be-7).

The licensee collected monthly ocean water samples from locations in the vicinity of

each station discharge and from the control location. The samples were analyzed for

naturally-occurring and licensee-related radionuclides. Quarterly composite ocean

water samples were analyzed for tritium. Naturally occurring potassium-40 (K-40) was

detected in all ocean water samples obtained in 2005. No licensee-related

radionuclides were detected in ocean water samples during 2005.

Drinking water samples were collected on a monthly basis from one indicator location

and from a control location. Samples were analyzed for tritium, gross beta, and 26

naturally-occurring and licensee-related radionuclides. No station-related radionuclides

were detected in drinking water during 2005.

Fish, crustacea and mollusks, were collected on a semi-annual basis at the SONGS

Unit I outfall and from a control location. The flesh portion of each sample type was

analyzed for 26 station-related and naturally-occurring radionuclides. Naturally-

occurring K-40 was detected in most marine samples collected during 2005. No

plant-related isotopes were reported above the minimum detectable concentration

(MDC).

The licensee conducted an internal quality assurance audit of the ODCM program

during August-September 2004, which was reviewed in a previous inspection. The next

audit of this area was scheduled for August 2006.

In summary, the licensee concluded that the site had a negligible radiological

environmental impact during 2005. The inspector found that the sample results

supported this conclusion. Further, no adverse trends were identified.

-9-

4.3 Conclusions

The licensees programs for monitoring radioactive liquid and gaseous effluent releases

and environmental monitoring were in compliance with license requirements. All

required samples had been collected, no sample result exceeded applicable limits, and

no adverse trends were identified.

5 Exit Meeting Summary

The inspector presented the preliminary inspection results to members of licensee

management at the exit meeting on July 21, 2006. The licensee did not identify as

proprietary any information provided to, or reviewed by, the inspector.

ATTACHMENT

PARTIAL LIST OF PERSONS CONTACTED

Licensee

D. Brieg, Station Manager

S. Enright, Unit 1 Health Physics Manager

N. Hansen, Technical Specialist, Environmental

M. Kelly, Engineer, Nuclear Regulatory Affairs

M. Kirby, Operations Supervisor Unit 1

M. Mason, Unit 1 Health Physics Supervisor

J. Morales, Manager, Decommissioning

J. Scott, Technical Specialist, Nuclear Regulatory Affairs

INSPECTION PROCEDURES USED

IP 36801 Organization, Management and Cost Controls

IP 37801 Safety Reviews, Design Changes, and Modifications

IP 71801 Decommissioning Performance and Status Review

IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring

ITEMS OPENED AND CLOSED

Opened

None

Closed

None

Discussed

None

LIST OF ACRONYMS

AREOR Annual Radiological Environmental Operating Report

ARERR Annual Radioactive Effluent Release Report

DSAR De-fueled Safety Analysis Report

ISFSI Independent Spent Fuel Storage Installation

ODCM Offsite Dose Calculation Manual

K-40 Potassium-40

LRTS Liquid Radwaste Treatment System

MDC Minimum Detectable Concentration

REMP Radiological Environmental Monitoring Program

SCE Southern California Edison Company

TLDs Thermoluminescent Dosimeters

TQAM Topical Quality Assurance Manual