IR 05000528/2015007

IR 05000528, 529, 530/2015007; and 07200044/2015001; on 02/22-26/2015; Palo Verde Nuclear Generating Station Units 1, 2, 3, and Independent Spent Fuel Storage Installation (Isfsi); Routine ISFSI Inspection Report

ML15086A433
Person / Time
Site:	Palo Verde
Issue date:	03/27/2015
From:	Ray Kellar NRC/RGN-IV/DNMS/RSFSB
To:	Edington R Arizona Public Service Co
References
IR 2015001, IR 2015007
Download: ML15086A433 (29)

Text

March 27, 2015

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, 3, AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

INSPECTION REPORT 05000528/2015007, 05000529/2015007, 05000530/2015007, AND 07200044/2015001

Dear Mr. Edington:

This letter refers to a routine inspection conducted on February 22-26, 2015, of the dry cask storage activities associated with your Independent Spent Fuel Storage Installation (ISFSI).

The enclosed inspection report documents the inspection results which were discussed on February 26, 2015 with Mr. Dwight Mims and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspection reviewed compliance with the requirements specified in the NAC International (NAC) Universal Multi-Purpose Canister System (UMS) Certificate of Compliance No. 1015 and the associated Technical Specifications, the NAC-UMS Final Safety Analysis Report (FSAR),

and Title 10 of the Code of Federal Regulations (CFR) Part 72, Part 50, and Part 20. Within these areas, the inspection included a review of radiation safety, cask thermal monitoring, quality assurance (QA), your corrective action program, safety evaluations, observations of dry fuel loading activities, and changes made to your ISFSI program since the last routine ISFSI inspection that was conducted by the U.S. Nuclear Regulatory Commission (NRC). The ISFSI facility was found to be in good physical condition. No violations of NRC regulations were identified.

In accordance with title 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Document Access 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, or proprietary 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 817-200-1191 or Mr. Lee Brookhart at 817-200-1549.

Sincerely,

/RA/

Ray L. Kellar, P.E., Chief Repository & Spent Fuel Safety Branch Division of Nuclear Materials Safety Dockets: 50-528, 50-529, 50-530, 72-44 Licenses: NPF-41, NPF-51, NPF-74 Enclosure:

Inspection Report 05000528/2015007; 05000529/2015007; 05000530/2015007; 07200044/2015001 w/attachments:

1. Supplemental Information 2. Loaded Casks at Palo Verde Nuclear Generating Station ISFSI cc w/encl: Electronic Distribution

SUMMARY OF FINDINGS

IR 05000528, 529, 530/2015007; and 07200044/2015001; 02/22-26/2015; Palo Verde Nuclear

Generating Station Units 1, 2, 3, and Independent Spent Fuel Storage Installation (ISFSI);

Routine ISFSI Inspection Report The report covers an announced inspection by one regional inspector and one inspector-in-training. The significance of any Part 50 findings are indicated by their color (Green, White,

Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process. The cross-cutting aspect is determined using IMC 0310, Components Within the Cross-Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after the NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006. In accordance with the NRC Enforcement Policy, all of the Part 72 ISFSI inspection findings follow the traditional enforcement process and are not disposition through the Reactor Oversight Process or the Significance Determination Process.

A.

NRC-Identified Findings and Self-Revealing Findings

No findings were identified.

B. Licensee-Identified Violations

None.

PLANT AND ISFSI STATUS Palo Verde Nuclear Generating Station (PVNGS) Independent Spent Fuel Storage Installation (ISFSI) stored 124 loaded NAC International (NAC) vertical concrete casks (VCCs) at the time of the routine inspection. PVNGS was loading the 125th canister, which was the third canister in their nine cask loading campaign for the Unit 1 facility in this calendar year. Inspectors observed loading operations associated with cask number 125 at the time of the routine inspection. The licensee utilized a general Part 72 license in accordance with the NAC,

Universal Multi-Purpose Canister System (UMS), approved under Certificate of Compliance (CoC) No. 1015, Amendment 5 and the NAC UMS Final Safety Analysis Report (FSAR),

Revision 10. The version of the NAC UMS systems used by the licensee included the TSC-24, a 24 fuel bundle transportable storage canister (TSC), designed to hold 24 pressurized water reactor (PWR) fuel assemblies. The ISFSI at Palo Verde contained a large earthen berm within the ISFSI protected area which was outside the Part 50 protected area. The berm was 120 feet wide at the base, 12 feet wide at the top, and 18 feet tall. The earthen berm extended around the ISFSI pad on three sides, specifically on the east, west, and south. The ISFSI consisted of twelve large rectangular concrete storage pads. The concrete storage pads were approximately 285 feet long by 35 feet wide. Each storage pad was designed to accommodate 28 VCCs arranged in two parallel rows of 14 casks. The design capacity allowed for a total of 336 VCCs.

The licensee had loaded the casks on the southernmost pads deepest into the earthen berm.

REPORT DETAILS

4OA5 Other Activities

.1 Operations of an Independent Spent Fuel Storage Installation at Operating Plants

(60855.1)

a. Inspection Scope

(1) Quality Assurance Audits and Surveillances The Palo Verde Nuclear Assurance Department (NAD) had included ISFSI related activities in their audit and surveillance program. The licensee performed a focused audit of its ISFSI program once every two years. NAD ISFSI Audit Plan and Report 2014-010 (Audit Report), dated January 16, 2015, was reviewed during this inspection. The quality assurance (QA) audits performed by the licensee reviewed activities and documentation to determine the effectiveness of the dry fuel storage program to operate safely in accordance with the requirements in the NAC-UMS Certificate of Compliance, the FSAR, the QA program, and their 10 CFR Part 72 program.

The Audit Report reviewed five program elements and eight administrative elements of ISFSI operation, as well as providing follow up on deficiencies identified in the previous ISFSI audit. The program elements included program and licensing requirements, design control, operation, maintenance, and Special Nuclear Material (SNM). The administrative elements included organization and responsibilities, department document control, QA records, task/job qualifications, corrective action, self-assessment, nuclear safety culture, and industry experience.

The licensees QA audit determined that all five ISFSI program elements were being effectively implemented at PVNGS. Six of the eight administrative elements of ISFSI operation were found to be effective, and two were found to be deficient: QA records and corrective action. The QA records program element was found to be deficient because SNM inventory records were not turned over to Support Services within the specified time frame and previous corrective actions identified during the 2012 ISFSI Audit were found to be ineffective. The corrective actions program element was found to be deficient because of several failures to implement corrective actions in a timely manner, including nonconforming conditions associated with the Vertical Concrete Cask (VCC)

The 2014 Audit produced a total of ten Palo Verde Action Requests (PVARs).

Three PVARs were associated with the QA audit of the ISFSI program elements and seven PVARs were associated with the QA audit of the administrative elements. All ten PVARs were entered into the licensees Corrective Action Program. NRC inspectors reviewed the corrective actions related to the findings to ensure that the identified deficiencies were properly categorized based on their safety significance and properly resolved. All identified deficiencies had been properly categorized and resolved by the licensee.

The QA surveillance report issued since the last NRC ISFSI inspection was reviewed by the NRC inspectors. Arizona Public Service (APS) QA personnel led a Nuclear Utility Procurement Issues Committee (NUPIC) audit of the NAC International production facility in Norcross, GA. NUPIC is a partnership involving all domestic and several international nuclear utilities that evaluates suppliers furnishing safety-related components and services and commercial-grade items to nuclear utilities. The QA surveillance was documented in APS Audit Report Number: A-NAC1-14-06/NUPIC Audit No. 23744, dated July 9, 2014. The audit team reviewed the following activities:

order entry, design, licensing, software quality assurance, procurement, fabrication/assembly activities, tests, inspections, calibration, document control, nonconforming items, corrective action, training, internal audits, and records. The audit team concluded that NAC International Inc. was effectively maintaining and implementing their Nuclear Quality program and complied with 10 CFR 72 Subpart G.

(2) Radiological Conditions Related to Stored Casks The PVNGS ISFSI was located approximately 2,600 feet east of the Unit 2 reactor containment building outside of the sites Part 50 protected area (PA). The ISFSI consisted of 12 concrete pads, situated in three columns of four arranged east to west. Each pad was designed to hold 28 NAC-UMS storage casks configured in a two by 14 array. The Palo Verde ISFSI was protected on three sides by an earthen berm that exceeded the height of the spent fuel storage casks. The open side of the berm faces plant west. Outside of the berm, the ISFSI was protected on all sides by two exclusion fences. On the inside of the inner fence was a roped boundary facing the entrance to the ISFSI that was posted as a Radioactive Materials Area. No flammable or combustible materials, debris, or excessive vegetative growth were observed inside the ISFSI area. One hundred twenty-four VCCs were loaded with spent fuel at the time of the inspection. The 124 VCCs completed four of the 12 pads and almost half of a fifth pad. VCC number 125 was being loaded at the time of the NRC ISFSI inspection. The inspector found the 124 NAC-UMS casks to be in good physical condition.

Radiological conditions at the Palo Verde ISFSI were determined from the most recent radiological survey (dated January 22, 2015) and records from the previous three years of thermoluminescent dosimeter (TLD) monitoring results. There were eight TLD monitoring locations that were positioned outside of the ISFSI exclusion area fence, two TLDs per side.

A PVNGS radiation protection (RP) technician accompanied the NRC inspector during the walk-down of the ISFSI pad area. Radiological measurements were taken by the RP technician with a Geiger-Mueller detector to record gamma exposure rates. The NRC inspector carried an NRC issued Ludlum Model 19 scintillation detector (NRC number 016337, calibration due date of 7/21/2015) that was capable of measuring low level gamma radiation exposure rates in micro-Roentgens per hour (µR/h). Survey measurements were taken at ISFSI area fence locations, around the perimeter of the ISFSI pad, and at selected areas between VCCs.

A gamma background reading outside the power plant prior to entry into the ISFSI pad area was approximately 10 µR/h. Radiation readings taken along the fence-line showed radiation levels ranging from 17 to 41 µR/h. General area measurements inside the berm and on the storage pads ranged from 32 µR/h, at the far empty side of the ISFSI to 1 mR/h in areas adjacent to and between loaded casks. The radiological conditions of the ISFSI were as expected for the age and heat-load of the 124 loaded spent fuel storage casks. The licensee was properly posting and controlling the ISFSI pad area consistent with 10 CFR Part 20 requirements.

(3) Environmental Radiological Monitoring Program The primary purpose of the Palo Verde Radiological Environmental Monitoring Program (REMP) was to evaluate the radiological impacts that reactor operations and stored radioactive materials may have on the local environment. The REMP was focused on measuring airborne (gaseous and particulate), liquid effluent, and direct radiation levels onsite, at the site boundary, and at offsite locations. The REMP monitored direct radiation impacts using TLDs. The licensee had established 50 REMP TLD monitoring stations for measuring and recording dose rates continuously throughout the year. Sixteen of those monitoring locations formed an inner ring at the site boundary, one in each meteorological sector. By design, there were no airborne or liquid effluents released from the Palo Verde ISFSI. NRC received the Annual Radioactive Effluent Release Reports for 2012 (ML13128A007) and 2013 (ML14125A295) for PVNGS, which confirmed that the ISFSI did not produce any effluent radioactive releases during 2012 or 2013.

The PVNGS ISFSI was monitored for direct radiation using TLDs that included direct gamma and neutron dose. The ISFSI TLDs were mounted on polymer phantoms to simulate the presence of a human body. This allowed for a more accurate neutron dose assessment. REMP TLDs only measured direct gamma dose. The TLD data for the ISFSI and the TLD data for the REMP were handled by different programs at PVNGS for different purposes. The ISFSI TLD monitoring was performed by the Palo Verde Area Monitoring Program to track radiological exposures near the ISFSI boundary to ensure that NRC occupational limits for unmonitored individuals were not exceeded. The REMP monitoring was conducted by APS for PVNGS to provide an annual assessment of the licensees total impacts to the environment, which includes contributions from the ISFSI.

ISFSI TLDs were placed at eight monitoring locations outside the outer exclusion fence. The TLD monitoring results from 2012, 2013, and 2014 were reviewed by NRC inspectors (see Table 1, below). The TLDs were collected and replaced each quarter of the year.

Table 1: PVNGS ISFSI Pad TLD Monitoring Data in µrem/h ISFSI TLD 3-Year Location (outside of fence) 2012 2013 2014 Location # Average South Fence SW TLD (gamma) 13.7 13.8 13.9 13.8 (neutron) 0.6 0 0 0.2 (total) 14.3 13.8 13.9 14.0 South Fence SE TLD (gamma) 21.6 24.1 23.8 23.2 (neutron) 7.9 9.8 4.6 7.4 (total) 29.5 33.9 28.4 30.6 East Fence SE TLD (gamma) 21.0 22.2 21.9 21.7 (neutron) 7.3 8.1 4.0 6.5 (total) 28.3 30.3 25.9 28.2 East Fence NE TLD (gamma) 20.0 20.6 21.5 20.7 (neutron) 8.2 8.7 3.4 6.8 (total) 28.2 29.3 24.9 27.5 North Fence NE TLD (gamma) 18.3 19.0 19.4 18.9 (neutron) 7.1 6.5 3.4 5.7 (total) 25.4 25.5 22.8 24.6 North Fence NW TLD (gamma) 15.0 14.4 15.3 14.9 (neutron) 2.0 1.8 0.3 1.4 (total) 17.0 16.2 15.6 16.3 West Fence NW TLD (gamma) 14.3 13.8 14.6 14.2 (neutron) 0 0.8 0 0.3 (total) 14.3 14.6 14.6 14.5 West Fence SW TLD (gamma) 13.6 14.0 14.4 14.0 (neutron) 0.3 0.3 0 0.2 (total) 13.9 14.3 14.4 14.2 NRC Inspectors verified the radiation exposure rates at each TLD monitoring location during the ISFSI walk-down. The highest average annual dose rate, approximately 270 mrem per year (30.6 µrem/h), was measured at the TLD #52 location. The three-year average of all ISFSI TLD monitoring locations has been trending upward as compared to the results of the previous three-year average (2010 - 2012) documented in the inspection report dated April 2, 2013 (ML13094A435). All accessible areas near the PVNGS ISFSI boundary, however, were below the 10 CFR 20.1502(a)(1) limit, of 500 mrem per year for unmonitored workers.

The yearly results of the REMP were compiled in an Annual Radiological Environmental Operating Report (AREOR). NRC reviewed the PVNGS AREORs for 2012 (ML13128A006), issued April 26, 2013 and 2013 (ML14129A007), issued May 2, 2014. The AREORs did not include the TLD direct radiation monitoring results for the ISFSI, but provided reporting and analyses for the REMP TLD monitoring results.

The PVNGS ISFSI was located 4,000 feet (0.8 miles) from the nearest site boundary monitoring location in the east sector. The REMP TLD monitoring site at the site boundary in closest proximity to the ISFSI was TLD #17. TLD monitoring locations #6 and #44 were control monitoring stations located 31 miles south-southeast and 35 miles east-northeast, respectively, from PVNGS. These TLDs can be treated as radiological backgrounds and have been averaged for this purpose (see Table 2, below).

Table 2, PVNGS Site Boundary TLD Result near ISFSI in mrem/yr TLD Site Station and Location 2012 2013

1. 17 E Sector, 4,000 feet east of ISFSI 98.2 96.9

1. 6 (control) SSE Sector, 31 miles from PVNGS 94.8 99.7

1. 44 (control) ENE Sector, 35 miles from PVNGS Table 2 (above) shows that direct radiation from the ISFSI and Part 50 activities had a negligible impact on site boundary ambient radiation levels. REMP results show that the site boundary dose at TLD #17 was slightly above background for 2012 and slightly below background in 2013. Correcting the 2012 value for background yielded a net annual dose of 3.4 mrem. This was well below the 10 CFR 72.104(a)(2) requirement of less than 25 mrem annual dose equivalent to any real individual located beyond the site controlled area. The radiological influence of the ISFSI on this site boundary location was minimal.

(4) Records Related to Fuel Stored in the Casks A review of dry fuel storage records for canisters 102 through 125 were selected to determine whether adequate descriptions of the spent fuel stored in each cask was documented as a permanent record as required by 10 CFR 72.212(b)(12). In addition, the fuel contents of these casks were verified against NAC CoC 1015 Technical Specification requirements for PWR fuel assemblies loaded into a TSC-24 canister. The spent fuel contents of the 24 selected casks were recorded in Analysis Report Numbers RE-02-C18-2013-003, RE-03-C17-2013-012, RE-03-C17-013, RE-02-C18-2013-003, RE-03-C18-2014-003, RE-C18-2014-010, RE-02-C19-2014-011, RE-01-C-19-2015-002, and RE-01-C19-2015-003. These reports included the TSC loading maps and fuel assembly qualification data, including fuel assembly identifiers, decay heat (kW), cooling time (years), initial assembly average U-235 enrichment (%), burn-up values (MWd/MTU), and other fuel assembly characterization information. Select fuel data is tracked by cask on Attachment 2 of this inspection report. PVNGS was in compliance with all applicable license and FSAR requirements for the fuel stored at the ISFSI and met retrievability requirements for storage of spent fuel records.

(5) Technical Specification 3.1.6, Cask Temperature Monitoring Technical Specification 3.1.6 required the casks heat removal system to be operable during storage on the ISFSI pad. Surveillance Requirement 3.1.6.1 required the licensee to verify daily the difference between the ISFSI ambient temperature and the average outlet air temperature as 102 degrees F or visually verify all four air inlet or outlet screens were unobstructed once each day. All casks in storage on the ISFSI pad were equipped with temperature monitoring equipment.

The licensee performed daily temperature monitoring for compliance with Technical Specification 3.1.6.1. Whenever the temperature monitoring equipment was malfunctioning or not in operation for a cask, the licensee performed daily vent inspections for that particular cask.

The licensee utilized Procedure 40ST-9ZZM1 Operations Mode 1 Surveillance Logs, Revision 63, during normal operations to comply with the Technical Specification 3.1.6. The procedures required operators to verify that the difference in the ambient temperature and each cask outlet temperature was < 90 degrees F.

If the acceptance criteria was not met, the operators were required to check the affected cask vent openings and remove any blockages, if found.

Documentation was reviewed for the months of September 2013, December 2013, February 2014, and July 2014 for compliance with Technical Specification 3.1.6. Of the four months selected for review, temperature monitoring was performed daily as required. The provided documentation showed a daily printout of the difference between the ambient temperature and each casks temperature. For all the days selected for review, no temperature difference between the ambient and a casks vents were found to be > 90 degrees.

(6) Corrective Action Program A list of Condition Reports (CRs) issued since the last NRC inspection in February of 2014 was provided by the licensee for the cask handling cranes from each unit and the ISFSI operations. Issues were processed in accordance with Procedure 90DP-0IP10, Condition Reporting, Revision 57. When a problem was identified the licensee documented the issue as a PVAR in the licensees corrective action program. Once a PVAR was initiated, the Action Request Review Committee determined if a Condition Report/Disposition Request (CRDR) per Procedure 90DP-0IP10 Condition Reporting, Revision 53 was required.

Of the list of PVARs/CRDRs provided relating to the ISFSI and the cask handling cranes, 29 documents were selected by the NRC inspectors for further review. The PVARs/CRDRs related to a variety of issues. The PVARs/CRDRs reviewed were well documented and properly categorized based on the safety significance of the issue. The corrective actions taken were appropriate for the situations. Based on the level of detail of the corrective action reports, the licensee demonstrated a high attention to detail in regard to the maintenance and operation of their ISFSI program and the cask handling cranes. No NRC safety concerns were identified related to the PVARs/CRDRs reviewed.

(7) Preparation of Loading Activities The inspectors requested documentation related to maintenance of the fuel building cask handling crane for Unit 1, the annual maintenance of the licensees special lifting devices, and the calibration of various gauges associated with the loading activities.

Documents were reviewed that demonstrated that the Unit 1 cask handling crane was inspected on an annual basis in accordance with American Society of Mechanical Engineers (ASME) B30.2 prior to the 2015 loading campaign. PVNGS utilized Work Order (WO) 4437112 dated October 21, 2014, to perform the annual maintenance in October of 2014.

The annual maintenance as required by American National Standards Institute (ANSI) N14.6 for special lifting devices was completed for the following special lifting devices: the Safelift (Lift Beam) and the canister shield lift rig. Documentation reviewed included WO 4465187 and associated non-destructive examination documentation associated with the testing. All equipment passed the magnetic particle, liquid penetrant, and dimensional testing.

The FSAR Section 9.2.2 required annual visual inspections of the transfer cask lifting trunnions, shield door, and shield door rails for permanent deformation and cracking. In addition, dimensional inspection of load-bearing components and a nondestructive examination of the major load-bearing welds were required annually.

The transfer cask annual inspections for 2013 through 2014 were reviewed. The licensee implemented the annual inspections using WO 4165175, dated August 14, 2013 and WO 4414043, dated August 14, 2011. For each year, magnetic particle examination was the method of nondestructive examination utilized. No indications were identified during the visual, dimensional, or magnetic particle examination for the years reviewed.

Calibration documentation of the hydrostatic pressure gages and the vacuum drying gage were reviewed to ensure the equipment had been properly calibrated prior to the loading operations. All calibration certificates reviewed demonstrated that the gages were properly calibrated prior to the loading campaign. After each canister loading the licensee performed a post-calibration on the hydrostatic pressures gages to verify the calibration of the gages in accordance with AMSE Section III NB-6413.

(8) VCC and ISFSI Yearly Maintenance The NAC UMS FSAR, Section 9.2.1 required an annual inspection of the concrete casks that included visual examination of the concrete, vent screens, and other attached hardware for damage. If concrete defects were found that were larger than 1-inch in diameter and deeper than 1-inch, repair by grouting was required.

The annual visual inspections for 2013 through 2014 were reviewed. The 2013 annual inspection was documented in Component Observation Report (COR) 13-9-001, Revision 0. The 2014 report was documented in COR 14-9-001, Revision 0.

Both reports documented that no new indications of concrete pop-outs or voids

> 1/2-inch in depth, no indications of spalling or scaling, and no new indications of concrete reinforcing bar corrosion were observed. The deficiencies noted during the inspections included minor efflorescence in portions of concrete surfaces typically in the upper half of the cask, random map cracks ranging from hairline to 0.016 inches, and rust on VCC steel lifting lugs which was removed and touched up a corrosion-inhibiting coating. All other deficiencies noted, were minor superficial surface issues that did not affect the function of the casks.

(9) Cask Loading Observations Various loading activities were observed by the NRC inspectors during the course of the routine ISFSI inspection. PVNGS was in the process of loading canister #125 at the time of the inspection. The NRC inspectors observed the fuel movement activities to place spent fuel assemblies into canister #125. The licensees staff was experienced in moving the spent fuel assemblies and was proficient in locating the correct assembly, verifying the assembly, moving the assembly from the rack to the canister, and inserting the assembly into the assigned canister slot. The time from grappling the assembly, placing the assembly into the assigned canister slot, and returning to the next assigned spent fuel assembly was approximately six to seven minutes.

Selected welding and non-destructive examination activities were observed during the loading associated with canister #125. An automatic welding process was used to weld the canister lid. The automated welding machine utilized one weld head to weld the lid to shell weld. The welders operated the equipment remotely in a low dose rate area. Hydrogen monitoring was performed during the welding of the root weld. Additionally, the NRC inspectors observed the non-destructive dye penetrant exams conducted on the lid-to-shell weld, the TSC structural lid weld, and the welds on the vent and drain port covers. If any welding defects were found the defects were removed by the welders and subsequent NDE examinations passed with clear results.

Other activities that were observed by NRC inspectors during the loading of canister

1. 125 included the draining of the TSC, drying of the TSC, lifting the transfer cask and fully loaded TSC out of the cask loading pit, and downloading of the TSC into the VCC storage cask. The licensees cask handling crane was able to handle the heavy load without any observed problems.

(10) Vertical Cask Transporter Lifting Brackets PVNGS utilized a Vertical Cask Transport (VCT) to move the VCC from outside the fuel building to ISFSI pad. The FSAR section 8.1.3 allows a license to utilize a mobile lifting frame (or transporter) when the lift height is limited to 24 inches and the mobile lifting device follows the requirements of Section A5.6.c of the Technical Specifications. The NAC FSAR does not specifically address the type of the mobile lifting device or the lifting brackets that lift the VCC to transport the cask to the ISFSI at PVNGS. PVNGS utilized a 72.48 safety evaluation to evaluate the use of the VCT to transport the VCC to the ISFSI pad. The 72.48 safety evaluation, procedures, and process performed at PVGNS abided by the Technical Specification requirement of A5.6.a. limiting the lift height of the VCC to 24 inches.

Table 1.5-1, NUREG-1536 Compliance Matrix from the FSAR, Chapter 3 - Structural Evaluation stated that: the lifting equipment design and devices for lifting the system components that are important to safety must comply with American National Standards Institute (ANSI) Standard N14.6. The VCC is listed as a system component that is important to safety. ANSI N14.6, Section 6.3.1 requires that each special lifting device be subjected to either a load test or dimensional checks, non-destructive examination and a visual examination annually, not to exceed 14 months.

PVNGS had not been performing an annual inspection of the VCT lifting brackets used to lift the VCC in accordance with ANSI N14.6 Section 6.3.1. Since the lifting brackets of the VCT were not specifically identified in the NAC FSAR, PVGNS has placed this issue into their corrective action program to confer with NAC to understand if the lifting brackets of the VCT shall conform to the requirement listed in FSAR Table 1.5-1 and be in compliance with the ANSI N14.6 Standard. This applicability of the VCT lifting brackets to comply with the ANSI N14.6 Standard is being tracked as an Unresolved Item (URI 72-44/1501-01).

b. Findings

No findings were identified.

.2 Review of 10 CFR 72.212(b) Evaluations at Operating Plants (60856.1)

a. Inspection Scope

Changes to the 10 CFR 72.212 Evaluation Report were reviewed to verify site characteristics were still bounded by the NAC UMS cask systems design basis.

PVNGS had not made any changes to their 72.212 Evaluation Report since the last ISFSI inspection in February 2013. The 72.212 Evaluation Report was at Revision 11, dated January 18, 2013.

b. Findings

No findings were identified.

.3 Review of 10 CFR 72.48 Evaluations

a. Inspection Scope

The licensees 10 CFR 72.48 screenings and evaluations for ISFSI program changes and 50.59 screenings and evaluations for changes made to the cask handling cranes since the last NRC routine ISFSI inspection were reviewed to determine compliance with regulatory requirements. PVNGS had performed six 72.48 screens associated with changes to the ISFSI equipment or operations. No modifications had been performed on any of the cask handling cranes which had required a 50.59 screen. The licensee had not performed any 72.48 full safety evaluations for the ISFSI or any 50.59 full safety evaluations for the cask handling cranes since the last NRC inspection in February of 2013.

Inspectors reviewed the six 72.48 screens provided by the licensee. The licensee utilized Procedure 93DP-0LC07, 10 CFR 50.59 and 72.48 Screenings and Evaluations, Revision 26 to perform the 10 CFR 72.48 safety screening. None of the screenings reviewed required a full 10 CFR 72.48 safety evaluation. All screenings were determined to be adequately evaluated.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On February 26, 2015, the inspectors presented the inspection results to Mr. Dwight Mims, Senior Vice President, Regulatory & Oversight, and other members of the licensee staff. The licensee acknowledged the inspection details presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee Personnel B. Hansen, Department Leader, NFM D. Heckman, Compliance, Regulator Affairs M, Kohrt, Operations Manager M. McGhee, Department Leader, Regulatory Affairs D. Mims, Senior Vice President, Regulatory and Oversight H. Nelson, Director of Maintenance Projects C. Stephenson, Licensing, Regulatory Affairs S. Toone, Dry Cask Storage Engineering A. Wrape, Director of Fuel Management INSPECTION PROCEDURES USED IP 60855.1 Operations of an ISFSI at Operating Plants IP 60856.1 Review of 10 CFR 72.212(b) Evaluations at Operating Plants IP 60857 Review of 10 CFR 72.48 Evaluations LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 72-44/1501-01 URI VCT Lifting Bracket compliance with ANSI N14.6.

Discussed None Closed None

LIST OF

DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

4OA5.1 Other Activities

Drawings

NUMBER TITLE DATE

0-M-20150122-2 VSDS Standard Map Survey Report 01/22/15

Procedures

NUMBER TITLE REVISION

2DP-9NF01 Control of SNM Transfer and Inventory Rev. 45

78OP-9FX03 Spent Fuel Handling Machine Rev. 55

78OP-9ZZ02 NAC-UMS Cask Loading Operations Rev. 32

GQP-9.6 Visual Examinations of Welds Rev. 14

78ST-9DC01 Helium Testing of TSC Shield Lid Welds Rev. 7

PI-CNSTR-T-OP-210 Closure Welding of NAC Dry Cask Storage Canisters Rev. 7

for APS

GQP-9.2 High Temperature Liquid Penetrant Examination and Rev. 7

Acceptance Standards for Welds, Base Materials and

Cladding (50o - 350oF)

90DP-0IP10 Condition Reporting Rev. 57

93DP-0LC07 10 CFR 50.59 and 72.48 Screenings and Evaluations Rev. 26

93DP-0LC07-01 10 CFR 50.59 and 72.48 Administrative Guidelines Rev. 2

40ST-9ZZM1 Operations Mode 1 Surveillance Logs Rev. 62, 63

Design Basis Documents

NUMBER TITLE REVISION

PVNGS ISFSI 72.212 Evaluation Report Rev. 11

Certificate of Compliance 72-1015 NAC International Amendment 5

Inc., NAC-UMS System

NAC International FSAR for the UMS Cask System Rev. 10

-1-

Miscellaneous Documents

NUMBER TITLE REVISION / DATE

RE-02-C18-2013-003 U2C18 Spent Fuel Selection for Dry Casks 101-104 Rev. 1

RE-03-C17-2013-012 U3C17 Spent Fuel Selection for Dry Casks 105-106 Rev. 0

RE-02-C18-2013-013 U3C17 Spent Fuel Selection for Dry Casks 107-110 Rev. 0

RE-03-C18-2014-003 U3C18 Spent Fuel Selection for Dry Casks 111-113 Rev. 0

RE-03-C18-2014-010 U3C18 Spent Fuel Selection for Dry Casks 114-116 Rev. 0

RE-02-C19-2014-011 U2C19 Spent Fuel Selection for Dry Casks 117-122 Rev.0

RE-01-C19-2015-002 U1C19 Spent Fuel Selection for Dry Casks 123-124 Rev. 0

RE-01-C19-2015-003 U1C19 Spent Fuel Selection for Dry Casks 125-131 Rev. 0

N/A NAD Audit Plan and Report 2014-010 ISFSI 01/16/15

N/A NUPIC Audit # 23744 / APS Audit # A-NAC1-14-06 07/09/14

N/A ISFSI TLD Trending 2003 - Present N/A

COR-13-9-001 VCC Annual Inspection Rev. 0

COR-13-9-002 ISFSI berms, culverts, ditches, etc., inspections Rev. 0

COR 14-9-002 ISFSI berms, culverts, ditches, etc., inspections Rev. 0

COR-14-9-001 VCC Annual Inspection Rev. 0

N/A PVNGS AREOR 2012 04/26/13

N/A PVNGS AREOR 2013 05/04/14

N/A PVNGS 2012 Annual Radioactive Effluent Release 04/30/13

Report

N/A PVNGS 2013 Annual Radioactive Effluent Release 04/30/14

Report

2.48 Screenings

2.48 Screening S-14-003 72.48 Screening S-14-002 72.48 Screening S-14-001

2.48 Screening S-13-003 72.48 Screening S-13-002 72.48 Screening S-13-001

Work Orders

WO 4437112 WO 4465187 WO 4165175 WO 4414043

PVARs/CRDRs

CRDR-4444058 CRDR-4459713 CRDR-4354531 CRDR-4605390

CRDR-4606985 CRDR-4601795 CRDR-4563698 CRDR-4558044

CRDR-4555811 CRDR-4548986 CRDR-4518912 CRDR-4459713

CRDR-4444078 CRDR-4424784 CRDR-4421994 CRDR-4386426

CRDR-4396605 CRDR-4356970 CRDR-4354530 CRDR-4353777

CRDR-4335239 CRDR-4562047 CRDR-4534473 CRDR-4558044

PVAR-4628208 PVAR-4627111 PVAR-4627295 CRDR-4627418

PVAR-4455514

-2-

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

ANSI American National Standards Institute

APS Arizona Public Service

AREOR Annual Radiological Environmental Operating Report

ASME American Society of Mechanical Engineers

CE Combustion Engineering

CFR Code of Federal Regulations

CoC Certificate of Compliance

COR Component Observation Report

CRDR Condition Report/Disposition Report

DNMS Division of Nuclear Material Safety

F Fahrenheit

FSAR Final Safety Analysis Report

IMC Inspection Manual Chapter

IP inspection procedure

ISFSI Independent Spent Fuel Storage Installation

kW killo-watt

mR milliRoentgen

micro(µ)R/hr microRoentgen per hour

micro(µ)rem/hr microRoentgen equivalent man per hour

MPC multipurpose canister

mrem milliRoentgen equivalent man

MWD/MTU megawatt days/metric ton uranium

NAD Nuclear Assurance Department

NDE non-destructive examination

NRC U.S. Nuclear Regulatory Commission

NUPIC Nuclear Utility Procurement Issues Committee

PA Protected Area

PVAR Palo Verde Action Request

PVNGS Palo Verde Nuclear Generating Station

PWR pressurized water reactor

QA quality assurance

REMP Radiological Environmental Monitoring Program

RP radiation protection

SNM Special Nuclear Material

TLD thermoluminescent dosimeter

TFR transfer cask

TSC transportable storage canister

UMS Universal Multi-Purpose Canister System

VCC vertical concrete cask

WO work order

-3-

ATTACHMENT 2:

LOADED CASKS AT THE PALO VERDE NUCLEAR GENERATING STATION ISFSI

PERSON-

LOADING VCC Canister DATE HEAT LOAD BURNUP MAXIMUM FUEL

Unit REM

ORDER ID No. ID No. ON PAD (kW) MWd/MTU (max) ENRICHMENT %

DOSE

AMZDNE001 AMZDFX001 Unit 2 3/15/03 7.59 42,833 4.0334 0.552

AMZDNE002 AMZDFX002 Unit 2 4/15/03 7.76 41,841 4.0368 0.402

AMZDNE003 AMZDFX003 Unit 2 5/15/03 10.17 40,737 4.0397 0.507

AMZDNE004 AMZDFX004 Unit 2 5/29/03 10.04 40,408 4.0098 0.351

AMZDNE005 AMZDFX005 Unit 2 6/12/03 10.96 38,357 4.044 0.260

AMZDNE006 AMZDFX008 Unit 1 7/24/03 10.37 42,318 4.050 0.286

AMZDNE007 AMZDFX007 Unit 1 8/07/03 10.48 42,214 4.046 0.262

AMZDNE008 AMZDFX006 Unit 1 8/21/03 11.03 42,168 4.057 0.325

AMZDNE009 AMZDFX009 Unit 1 9/05/03 11.52 42,050 4.057 0.253

AMZDNE010 AMZDFX010 Unit 1 9/18/03 7.14 30,134 3.309 0.251

AMZDNE011 AMZDFX011 Unit 3 1/23/04 12.16 39,735 3.905 0.259

AMZDNE012 AMZDFX012 Unit 3 2/06/04 12.13 39,574 3.917 0.239

AMZDNE013 AMZDFX013 Unit 3 2/26/04 12.26 39,821 3.913 0.297

AMZDNE014 AMZDFX014 Unit 3 3/11/04 11.52 39,640 3.919 0.207

PERSON-

LOADING VCC Canister DATE HEAT LOAD BURNUP MAXIMUM FUEL

Unit REM

ORDER ID No. ID No. ON PAD (kW) MWd/MTU (max) ENRICHMENT %

DOSE

AMZDNE015 AMZDFX015 Unit 3 3/25/04 11.73 39,180 3.917 0.218

AMZDNE016 AMZDFX016 Unit3 5/27/04 11.74 39,939 3.913 0.202

AMZDNE017 AMZDFX017 Unit 2 7/15/04 10.65 44,693 4.041 0.195

AMZDNE018 AMZDFX018 Unit 2 7/29/04 10.66 44,637 4.050 0.164

AMZDNE019 AMZDFX019 Unit 2 8/12/04 9.71 43,369 4.030 0.137

AMZDNE020 AMZDFX020 Unit 2 8/26/04 9.73 43,362 4.043 0.095

AMZDNE021 AMZDFX021 Unit 2 9/10/04 9.73 43,350 4.044 0.125

AMZDNE022 AMZDFX022 Unit 2 9/23/04 9.73 43,205 4.036 0.115

AMZDNE023 AMZDFX023 Unit 1 1/22/05 12.28 44,953 4.032 0.165

AMZDNE024 AMZDFX024 Unit 1 3/17/05 12.28 44,973 4.035 0.178

AMZDNE025 AMZDFX025 Unit 1 3/24/05 12.05 44,973 4.033 0.193

AMZDNE026 AMZDFX026 Unit 1 3/03/05 12.40 44,992 4.033 0.097

AMZDNE027 AMZDFX027 Unit 1 3/10/05 12.40 44,608 4.032 0.126

AMZDNE028 AMZDFX028 Unit 1 3/30/05 12.06 44,957 4.033 0.115

AMZDNE029 AMZDFX029 Unit 3 8/03/05 10.33 41,361 3.528 0.144

AMZDNE030 AMZDFX030 Unit 3 8/11/05 10.24 41,603 3.528 0.142

-2-

PERSON-

LOADING VCC Canister DATE HEAT LOAD BURNUP MAXIMUM FUEL

Unit REM

ORDER ID No. ID No. ON PAD (kW) MWd/MTU (max) ENRICHMENT %

DOSE

AMZDNE031 AMZDFX031 Unit 3 8/19/05 11.60 44,247 3.970 0.116

AMZDNE032 AMZDFX032 Unit 3 8/31/05 11.56 43,594 4.000 0.105

AMZDNE033 AMZDFX033 Unit 3 9/08/05 11.57 44,247 3.992 0.104

AMZDNE034 AMZDFX034 Unit 3 9/16/05 11.57 43,594 4.001 0.094

AMZDNE035 AMZDFX035 Unit 2 1/20/06 11.98 44,849 4.384 0.100

AMZDNE036 AMZDFX036 Unit 2 1/27/06 12.00 44,877 4.386 0.091

AMZDNE037 AMZDFX037 Unit 2 2/09/06 11.98 44,877 4.388 0.064

AMZDNE038 AMZDFX038 Unit 2 2/17/06 11.98 44,877 4.386 0.066

AMZDNE039 AMZDFX039 Unit 2 2/24/06 11.99 44,877 4.390 0.078

AMZDNE040 AMZDFX040 Unit 2 3/03/06 12.01 44,390 4.383 0.051

AMZDNE041 AMZDFX041 Unit 2 3/10/06 12.02 43,877 4.380 0.064

AMZDNE042 AMZDFX042 Unit 1 7/21/06 8.52 44,801 4.162 0.035

AMZDNE043 AMZDFX043 Unit 1 7/29/06 8.39 44,801 4.149 0.042

AMZDNE044 AMZDFX044 Unit 1 8/04/06 8.41 44,801 4.148 0.035

AMZDNE045 AMZDFX045 Unit 1 8/18/06 8.41 44,801 4.144 0.041

AMZDNE046 AMZDFX046 Unit1 8/25/06 8.46 44,706 4.146 0.044

-3-

PERSON-

LOADING VCC Canister DATE HEAT LOAD BURNUP MAXIMUM FUEL

Unit REM

ORDER ID No. ID No. ON PAD (kW) MWd/MTU (max) ENRICHMENT %

DOSE

AMZDNE047 AMZDFX047 Unit 1 9/01/06 8.45 44,706 4.146 0.032

AMZDNE048 AMZDFX048 Unit 3 4/06/07 9.07 44,841 4.287 0.058

AMZDNE049 AMZDFX049 Unit 3 4/13/07 8.81 44,778 4.287 0.058

AMZDNE050 AMZDFX050 Unit 3 4/20/07 8.76 44,778 4.266 0.049

AMZDNE051 AMZDFX051 Unit 3 4/28/07 8.80 44,778 4.272 0.049

AMZDNE052 AMZDFX052 Unit 3 5/04/07 8.67 44,841 4.269 0.046

AMZDNE053 AMZDFX053 Unit 3 5/11/07 8.64 44,841 4.298 0.043

AMZDNE054 AMZDFX054 Unit 2 9/25/08 9.46 44,822 4.208 0.074

AMZDNE055 AMZDFX055 Unit 2 12/06/08 9.54 44,822 4.208 0.107

AMZDNE056 AMZDFX056 Unit 2 12/16/08 9.53 44,822 4.206 0.051

AMZDNE057 AMZDFX057 Unit 2 12/31/08 9.56 44,822 4.387 0.040

AMZDNE058 AMZDFX058 Unit 1 2/28/09 12.70 44,850 4.375 0.096

AMZDNE059 AMZDFX059 Unit 1 3/10/09 14.17 53,665 4.378 0.124

AMZDNE060 AMZDFX060 Unit 1 3/20/09 14.18 52,637 4.379 0.089

AMZDNE061 AMZDFX061 Unit 1 6/09/09 14.21 52,874 4.381 0.121

AMZDNE062 AMZDFX062 Unit 1 6/24/09 14.23 52,915 4.379 0.096

-4-

PERSON-

LOADING VCC Canister DATE HEAT LOAD BURNUP MAXIMUM FUEL

Unit REM

ORDER ID No. ID No. ON PAD (kW) MWd/MTU (max) ENRICHMENT %

DOSE

AMZDNE063 AMZDFX063 Unit 3 8/08/09 13.61 51,122 4.288 0.108

AMZDNE064 AMZDFX064 Unit 3 8/21/09 13.61 51,122 4.289 0.094

AMZDNE065 AMZDFX065 Unit 3 8/28/09 13.84 49,692 4.381 0.096

AMZDNE066 AMZDFX066 Unit 3 9/04/09 13.86 49,692 4.384 0.106

AMZDNE067 AMZDFX067 Unit 3 9/11/09 13.88 49,692 4.387 0.104

AMZDNE068 AMZDFX068 Unit 2 1/29/10 12.73 49,797 4.387 0.099

AMZDNE069 AMZDFX069 Unit 2 2/05/10 12.73 49,797 4.384 0.097

AMZDNE070 AMZDFX070 Unit 2 2/12/10 12.73 49,797 4.390 0.096

AMZDNE071 AMZDFX071 Unit 2 2/26/10 14.02 49,487 4.384 0.091

AMZDNE072 AMZDFX072 Unit 2 3/05/10 14.02 49,487 4.386 0.102

AMZDNE073 AMZDFX073 Unit 2 3/12/10 13.97 49,487 4.390 0.089

AMZDNE074 AMZDFX074 Unit 1 8/07/10 12.80 51,421 4.401 0.084

AMZDNE075 AMZDFX075 Unit 1 8/13/10 12.80 51,528 4.402 0.060

AMZDNE076 AMZDFX076 Unit 1 8/20/10 12.80 51,529 4.400 0.062

AMZDNE077 AMZDFX077 Unit 1 9/03/10 12.81 52,548 4.407 0.060

AMZDNE078 AMZDFX078 Unit 1 9/10/10 12.41 53,779 4.388 0.059

-5-

PERSON-

LOADING VCC Canister DATE HEAT LOAD BURNUP MAXIMUM FUEL

Unit REM

ORDER ID No. ID No. ON PAD (kW) MWd/MTU (max) ENRICHMENT %

DOSE

AMZDNE079 AMZDFX079 Unit 3 1/28/11 13.01 52,283 4.406 0.169

AMZDNE080 AMZDFX080 Unit 3 2/04/11 12.73 50,399 4.401 0.117

AMZDNE081 AMZDFX081 Unit 3 2/11/11 12.59 50,399 4.404 0.086

AMZDNE082 AMZDFX082 Unit 3 2/25/11 12.58 50,457 4.401 0.074

AMZDNE083 AMZDFX083 Unit 3 3/04/11 12.62 51,402 4.403 0.061

AMZDNE084 AMZDFX084 Unit 3 3/11/11 12.66 51,402 4.404 0.076

AMZDNE085 AMZDFX085 Unit 2 7/29/11 14.03 51,119 4.396 0.109

AMZDNE086 AMZDFX086 Unit 2 8/06/11 14.04 51,119 4.400 0.140

AMZDNE087 AMZDFX087 Unit 2 8/12/11 14.06 51,116 4.391 0.108

AMZDNE088 AMZDFX088 Unit 2 8/26/11 14.06 51,116 4.407 0.106

AMZDNE089 AMZDFX089 Unit 2 9/02/11 14.05 51,046 4.400 0.101

AMZDNE090 AMZDFX090 Unit 1 1/20/12 13.89 48,347 4.394 0.138

AMZDNE091 AMZDFX091 Unit 1 1/27/12 13.90 47,489 4.392 0.119

AMZDNE092 AMZDFX092 Unit 1 2/10/12 13.91 49,253 4.390 0.118

AMZDNE093 AMZDFX094 Unit 1 2/17/12 13.90 48,750 4.392 0.100

AMZDNE094 AMZDFX096 Unit 1 2/24/12 13.92 48,388 4.394 0.089

-6-

PERSON-

LOADING VCC Canister DATE HEAT LOAD BURNUP MAXIMUM FUEL

Unit REM

ORDER ID No. ID No. ON PAD (kW) MWd/MTU (max) ENRICHMENT %

DOSE

AMZDNE095 AMZDFX095 Unit 1 8/18/12 13.79 51,957 4.406 0.104

AMZDNE096 AMZDFX093 Unit 1 8/24/12 13.77 49,876 4.407 0.085

AMZDNE097 AMZDFX097 Unit 1 8/31/12 13.77 49,876 4.412 0.095

AMZDNE098 AMZDFX098 Unit 1 9/07/12 13.74 49,876 4.404 0.084

AMZDNE099 AMZDFX099 Unit 2 2/09/13 13.08 49,876 4.391 0.135

100 AMZDNE100 AMZDFX100 Unit 2 2/15/13 13.08 49,886 4.655 0.109

101 AMZDNE101 AMZDFX101 Unit 2 2/25/13 13.08 49,895 4.655 0.113

2 AMZDNE102 AMZDFX103 Unit 2 05/10/13 13.17 54,062 4.646 0.155

103 AMZDNE103 AMZDFX106 Unit 2 05/17/13 13.26 50,058 4.656 0.086

104 AMZDNE104 AMZDFX104 Unit 2 05/24/13 14.86 48,548 4.206 0.113

105 AMZDNE105 AMZDFX105 Unit 3 08/13/13 13.62 54,507 4.410 0.136

106 AMZDNE106 AMZDFX102 Unit 3 08/24/13 13.62 54,507 4.406 0.191

107 AMZDNE107 AMZDFX107 Unit 3 08/30/13 13.43 54,507 4.403 0.075

108 AMZDNE108 AMZDFX108 Unit 3 09/30/13 13.45 54,507 4.401 0.136

109 AMZDNE109 AMZDFX109 Unit 3 12/13/13 13.44 54,507 4.407 0.156

110 AMZDNE110 AMZDFX110 Unit 3 02/14/14 13.42 52,971 4.402 0.102

-7-

PERSON-

LOADING VCC Canister DATE HEAT LOAD BURNUP MAXIMUM FUEL

Unit REM

ORDER ID No. ID No. ON PAD (kW) MWd/MTU (max) ENRICHMENT %

DOSE

111 AMZDNE111 AMZDFX111 Unit 3 02/21/14 13.54 48,507 4.404 0.107

2 AMZDNE112 AMZDFX112 Unit 3 02/28/14 13.55 48,704 4.409 0.085

113 AMZDNE113 AMZDFX113 Unit 3 03/07/14 13.56 48,501 4.404 0.070

114 AMZDNE114 AMZDFX114 Unit 3 05/16/14 13.4 49,388 4.411 0.100

115 AMZDNE115 AMZDFX115 Unit 3 05/27/14 13.39 49,388 4.412 0.073

116 AMZDNE116 AMZDFX116 Unit 3 05/30/14 13.33 45,139 4.409 0.084

117 AMZDNE117 AMZDFX117 Unit 2 07/18/14 12.96 54,554 4.381 0.089

118 AMZDNE118 AMZDFX118 Unit 2 07/25/14 12.96 54,554 4.391 0.078

119 AMZDNE119 AMZDFX119 Unit 2 08/01/14 12.95 54,554 4.385 0.094

20 AMZDNE120 AMZDFX120 Unit 2 08/08/14 13.17 54,554 4.390 0.075

21 AMZDNE121 AMZDFX121 Unit 2 08/29/14 13.22 54,542 4.386 0.091

2 AMZDNE122 AMZDFX122 Unit 2 09/05/14 13.31 54,542 4.654 0.070

23 AMZDNE123 AMZDFX123 Unit 1 02/13/15 12.70 48,792 4.407 0.089

24 AMZDNE124 AMZDFX124 Unit 1 02/20/15 12.75 51,006 4.404 0.102

25 AMZDNE125 AMZDFX125 Unit 1 02/27/15 13.09 49,387 4.515 0.124

-8-

NOTES: Heat load (kW) is the sum of the heat load values for all spent fuel assemblies in the cask

Burn-up is the value for the spent fuel assembly with the highest individual discharge burn-up

Fuel enrichment is the spent fuel assembly with the highest individual initial enrichment per cent of U-235

Casks #1 through 16 were loaded to CoC No. 1015, Amendment 2

Casks #17 through 34 were loaded to CoC No. 1015, Amendment 3

Casks #35 through 58 were loaded to CoC No. 1015, Amendment 4

Casks #59 through 125 were loaded to CoC No. 1015, Amendment 5

All casks are currently maintained under CoC No. 1015, Amendment 5, and FSAR Revision 10

-9-