11 • 26 • 2018
Inadequate Training and Supervision at Southern CA Nuclear Plant
Image by Swan Dive Media.
On November 8, the federal agency tasked with overseeing U.S. nuclear power plants released findings from a special inspection into the near-drop of a canister loaded with high level radioactive waste at Southern California Edison’s recently deactivated nuclear plant at San Onofre. The results are truly concerning.
The Surfrider Foundation is strongly opposed to permanent or long-term storage of radioactive waste at the deactivated San Onofre Nuclear Generating Station (SONGS) due to its proximity to the coastline, susceptibility to geological instability and location within a densely populated area. Surfrider recognizes the waste needs to be cooled onsite before it's moved and we demand that this is done as safely as possible, while also advocating the waste is moved as soon as possible to a consent-based, geologically stable permanent location away from the coast.
The overseeing agency, Nuclear Regulatory Commission (NRC), hosted a webinar earlier this month providing a descriptive account of the fuel transfer process at SONGS, and how canisters are downloaded into their VVM's (vertical ventilated modules) within the dry storage area (ISFSI). NRC also explained the near-drop event on August 3, 2018, and what inadequacies in training, procedures, and oversight by Edison and Holtec, the manufacturer, led to what could have been an 18-foot drop of a loaded canister. Note that no canister was actually dropped, and all fuel inside the canister and the canister itself is intact, but the fact that it could have happened is alarming.
The results of the inspection include two preliminary “Escalated Findings” and three preliminary “Severity Level IV Violations” procedures. The webinar slide on root cause analysis also states “San Onofre failed to provide [a]dquate procedures, [a]dequate training to support procedure, and [a]dequate oversight.”
Edison will not be able to resume loading until all of the inadequacies identified have been corrected and approved by the NRC, including:
Proper use of the required monitoring protocols during the loading process (those tasked with monitoring the download walked away from the download location, to the “low dose radiation area” which doesn't have a view of the actual downloading process);
More robust training of employees and operators (it was the first time that the employee operating the vertical transporter- the machine that moves and lowers the canister - actually loaded a canister, and he wasn't trained of proper protocols, what issues to look out for, or how to monitor the control panel, which was indicating that there was an issue);
Disclosure of differences between training methods and actual processes and their implications (operators practice lowering a canister into a VVM before handling loaded canisters, but the practice gear is different: the practice canister is smaller in diameter and the clearance between the canister and the VVM wall is larger, meaning the practice method is easier than the actual process, but trainees were not notified of this difference); and
Increased supervision and oversight by both Edison and Holtec (even though management knew it was the operator's first time loading, there was no manager or supervisor there to directly watch and guide him)
Once corrective actions have taken place, the NRC will work on penalties and enforcement actions for Edison's failures to meet the safety, notification, and training protocols required by their license.
Edison’s disregard to the community’s continual requests for use of the highest safety protocols and training efforts is severely disheartening. Join us in demanding that Edison employ the following safety protocols, training and public engagement for the remainder of the fuel transfer process, decommissioning process, and ongoing storage of spent fuel.
Surfrider Demands for Better Safety Protocols, Training and Public Engagement at SONGS
- Increased public transparency and timely notification of events
- At least one Holtec expert, one Edison supervisor, and one NRC representative onsite to directly oversee contractors during each fuel transfer
- More comprehensive training and supervision for personnel, including:
- Personnel-wide training on the differences between training processes/ materials and actual processes/ materials, and the ramifications
- Personnel-wide notification of issues experienced and open-sharing of operational knowledge
- More noticeable alarm systems when issues are detected, such as VCT control panel indications during loading
- Proper use of redundant safety systems
- Fixed CEC guiding rings that actually help guide the canister as intended during the loading process (the other Holtec UMAX facility had these repaired before loading, something SCE opted not to do)
- Retention of one spent fuel pool onsite for the duration waste is stored, or until another onsite method of waste retrieval/reloading becomes available
- 24/7 temperature monitoring on each canister and radiation monitoring along the perimeter
- Readily deployable plans for hazards including corrosion, flooding and saltwater exposure
- Development of thorough canister monitoring and readily deployable repair mechanisms
- Assurance that canisters remain transportable, including the release of a publicly available, third-party assessment of the canister integrity and expected transportability of each of the loaded canisters, with a focus on the identification and measurement of scratches from metal-metal contact caused during the alignment and download process
- Development of a sea and groundwater level rise vulnerability assessment using the State of California’s recently acknowledged extreme rise scenario, known as H++
- Development of a more robust and publicly available radiological environmental monitoring program at recreational areas near SONGS
To note, Edison has been receptive to several of these requests, including the development of a more robust radiological monitoring program in recreational areas near the plant. In addition to demanding that Edison employ the highest safety precautions and public notification procedures while the waste remain onsite, we need to continue to focus on the national problem of spent fuel, and the ultimate goal of getting the waste moved to a safer, permanent repository away from the ocean, as safely and quickly as possible.
Update November 28, 2018: NRC has released the final report on the special inspection, which is availablere here. The report confirms the webinar's findings of Level IV violations: “The three Severity Level IV violations are cited in the enclosed Notice and the circumstances surrounding them are described in detail in the subject inspection report. The violations involved failures to: (1) identify conditions potentially adverse to quality for placement into your corrective actions program; (2) establish an adequate program for training, proficiency testing, and certification for individuals involved in downloading operations; and (3) provide adequate procedures for dry cask storage operations involving downloading operations.”
Southern California Edison will now have one month to reply to this notice of violation, providing “(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” for each violation listed.