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San Onofre Nuclear Generating Station
San Onofre Nuclear Generating Station
P.O. Box 128
P.O. Box 128
San Clemente, California 92674-0128
San Clemente, California 92674-0128
SUBJECT:       NRC INSPECTION REPORT 50-206/03-10; 50-361/03-10; 50-362/03-10;
SUBJECT:
                72-41/03-01 FOR THE PRE-OPERATIONAL TESTING AND FIRST CANISTER
NRC INSPECTION REPORT 50-206/03-10; 50-361/03-10; 50-362/03-10;
                LOADING AT THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION
72-41/03-01 FOR THE PRE-OPERATIONAL TESTING AND FIRST CANISTER
LOADING AT THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION
Dear Mr. Ray:
Dear Mr. Ray:
NRC inspections were conducted between June 26 and October 1, 2003, at your San Onofre
NRC inspections were conducted between June 26 and October 1, 2003, at your San Onofre
nuclear generating station to evaluate the dry cask storage activities for your Independent Spent
nuclear generating station to evaluate the dry cask storage activities for your Independent Spent
Fuel Storage Installation (ISFSI). These inspections included observation of activities associated
Fuel Storage Installation (ISFSI). These inspections included observation of activities associated
with your pre-operational testing program and the loading of your first canister. The inspections
with your pre-operational testing program and the loading of your first canister. The inspections
were conducted to confirm compliance of your program and activities with the requirements
were conducted to confirm compliance of your program and activities with the requirements
specified in the license, technical specifications, Final Safety Analysis Report, the NRCs Safety
specified in the license, technical specifications, Final Safety Analysis Report, the NRCs Safety
Evaluation Report and 10 CFR Part 72. The enclosed report presents the results of these
Evaluation Report and 10 CFR Part 72. The enclosed report presents the results of these
inspections. The inspections found that activities were being performed in accordance with
inspections. The inspections found that activities were being performed in accordance with
procedural and regulatory requirements. No violations of NRC regulations were identified.
procedural and regulatory requirements. No violations of NRC regulations were identified.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its
In accordance with 10 CFR 2.790 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
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 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
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
response should not include any personal privacy, proprietary, or safeguards information so that it
can be made available to the Public without redaction.
can be made available to the Public without redaction.  
Should you have any questions concerning this inspection, please contact the undersigned at
Should you have any questions concerning this inspection, please contact the undersigned at
(817) 860-8191 or Mr. Vincent Everett, Senior Health Physicist, at (817) 860-8198.
(817) 860-8191 or Mr. Vincent Everett, Senior Health Physicist, at (817) 860-8198.
                                                Sincerely,
Sincerely,  
                                                /RA/
/RA/
                                                D. Blair Spitzberg, Ph.D., Chief
D. Blair Spitzberg, Ph.D., Chief
                                                Fuel Cycle and Decommissioning Branch
Fuel Cycle and Decommissioning Branch
Docket Nos.: 50-206; 50-361; 50-362; 72-41
Docket Nos.: 50-206; 50-361; 50-362; 72-41
License Nos.: DPR-13; NPF-10; NPF-15
License Nos.: DPR-13; NPF-10; NPF-15


Southern California Edison Company           -2-
Southern California Edison Company
Enclosure:
-2-
NRC Inspection Report
Enclosure:
50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01
NRC Inspection Report  
  50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01
cc w/enclosure:
cc w/enclosure:
Dwight E. Nunn, Vice President
Dwight E. Nunn, Vice President
Line 61: Line 63:
San Onofre Nuclear Generating Station
San Onofre Nuclear Generating Station
P.O. Box 128
P.O. Box 128
San Clemente, California 92674-0128
San Clemente, California 92674-0128
Michael R. Olson
Michael R. Olson
San Onofre Liaison
San Onofre Liaison
San Diego Gas & Electric Company
San Diego Gas & Electric Company
P.O. Box 1831
P.O. Box 1831
San Diego, California 92112-4150
San Diego, California 92112-4150
Mayor
Mayor  
City of San Clemente
City of San Clemente  
100 Avenida Presidio
100 Avenida Presidio  
San Clemente, California 92672
San Clemente, California 92672
Chairman, Board of Supervisors
Chairman, Board of Supervisors  
County of San Diego
County of San Diego  
1600 Pacific Highway, Room 335
1600 Pacific Highway, Room 335  
San Diego, California 92101
San Diego, California 92101
Ed Bailey, Radiation Program Director
Ed Bailey, Radiation Program Director
Radiologic Health Branch
Radiologic Health Branch
State Department of Health Services
State Department of Health Services
P.O. Box 942732 (MS 178)
P.O. Box 942732 (MS 178)
Sacramento, California 94327-7320
Sacramento, California 94327-7320
David Spath, Chief
David Spath, Chief
Division of Drinking Water and
Division of Drinking Water and  
Environmental Management
  Environmental Management  
P.O. Box 942732
P.O. Box 942732
Sacramento, California 94234-7320
Sacramento, California 94234-7320
James D. Boyd, Commissioner
James D. Boyd, Commissioner
California Energy Commission
California Energy Commission
1516 Ninth Street (MS 34)
1516 Ninth Street (MS 34)
Sacramento, California 95814
Sacramento, California 95814


Southern California Edison Company   -3-
Southern California Edison Company
-3-
Douglas K. Porter, Esq.
Douglas K. Porter, Esq.
Southern California Edison Company
Southern California Edison Company
2244 Walnut Grove Avenue
2244 Walnut Grove Avenue
Rosemead, California 91770
Rosemead, California 91770
Gary L. Nolff
Gary L. Nolff
Power Projects/Contracts Manager
Power Projects/Contracts Manager
Riverside Public Utilities
Riverside Public Utilities
2911 Adams Street
2911 Adams Street
Riverside, California 92504
Riverside, California 92504
Eileen M. Teichert, Esq.
Eileen M. Teichert, Esq.
Supervising Deputy City Attorney
Supervising Deputy City Attorney
City of Riverside
City of Riverside
3900 Main Street
3900 Main Street
Riverside, California 92522
Riverside, California 92522
Dr. Raymond Waldo
Dr. Raymond Waldo
Southern California Edison Company
Southern California Edison Company
San Onofre Nuclear Generating Station
San Onofre Nuclear Generating Station
P.O. Box 128
P.O. Box 128
San Clemente, California 92674-0128
San Clemente, California 92674-0128
A. Edward Scherer
A. Edward Scherer
Southern California Edison
Southern California Edison
San Onofre Nuclear Generating Station
San Onofre Nuclear Generating Station
P.O. Box 128
P.O. Box 128
San Clemente, California 92674-0128
San Clemente, California 92674-0128
Joseph J. Wambold, Vice President
Joseph J. Wambold, Vice President
Southern California Edison Company
Southern California Edison Company
San Onofre Nuclear Generating Station
San Onofre Nuclear Generating Station
P.O. Box 128
P.O. Box 128
San Clemente, California 92764-0128
San Clemente, California 92764-0128


Southern California Edison Company               -4-
Southern California Edison Company
-4-
bcc w/enclosure (via ADAMS e-mail distribution):
bcc w/enclosure (via ADAMS e-mail distribution):
EECollins
EECollins
Line 141: Line 145:
FCDB
FCDB
NBHolbrook
NBHolbrook
RIV Materials Docket Files - 5th Floor
RIV Materials Docket Files - 5th Floor  
ADAMS:   :Yes       9No           Initials: JVE
ADAMS: :Yes
:Publicly Available   9Non-Publicly Available         9Sensitive :Non-Sensitive
9No           Initials:   JVE  
DOCUMENT NAME: s:\dnms\fcdb\jve\So1-2003-010 jve.wpd final r:\_so1\So1-2003-10.wpd
:Publicly Available 9Non-Publicly Available
RIV:DNMS:FCDB           FCDB                       FCDB             FCDB
9Sensitive
JVEverett               EMGarcia                   RJEvans           TWDexter
:Non-Sensitive
/RA/                   /RA JVEverett via E/ /RA JVEverett via E/ /RA JVEverett via E/
DOCUMENT NAME: s:\\dnms\\fcdb\\jve\\So1-2003-010 jve.wpd     final r:\\_so1\\So1-2003-10.wpd
12/18/03               12/22/03                   12/18/03         12/18/03
RIV:DNMS:FCDB
NMSS:DWM:HLWB           NMSS:SFPO                 DRP:PBC           DRP:PBC
FCDB
JDParrott               RRTemps                   JFMelfi           MASitek
FCDB
/RA JVEverett via E/ /RA JVEverett via E/ /RA JVEverett via E/ /RA JVEverett via E/
FCDB
12/16/03               12/17/03                   12/15/03         1/6/04
JVEverett
DRP:PBC                 DRS:EMB                   NMSS:SFPO         C:FCDB
EMGarcia
RVAzua                 WCSifre                   ABBarto           DBSpitzberg
RJEvans
/RA JVEverett via E/ /RA JVEverett via E/ /RA JVEverett via E/ /RA/
TWDexter
12/29/03               12/18/03                   12/30/03         1/6/04
/RA/
OFFICIAL RECORD COPY                                     T=Telephone   E=E-mail F=Fax
/RA JVEverett via E/
/RA JVEverett via E/
/RA JVEverett via E/
12/18/03
12/22/03
12/18/03
12/18/03
NMSS:DWM:HLWB
NMSS:SFPO
DRP:PBC
DRP:PBC
JDParrott
RRTemps
JFMelfi
MASitek
/RA JVEverett via E/
/RA JVEverett via E/
/RA JVEverett via E/
/RA JVEverett via E/
12/16/03
12/17/03
12/15/03
1/6/04
DRP:PBC
DRS:EMB
NMSS:SFPO
C:FCDB
RVAzua
WCSifre
ABBarto
DBSpitzberg
/RA JVEverett via E/
/RA JVEverett via E/
/RA JVEverett via E/
/RA/
12/29/03
12/18/03
12/30/03
1/6/04
OFFICIAL RECORD COPY  
T=Telephone           E=E-mail       F=Fax


                                  ENCLOSURE
ENCLOSURE
                U.S. NUCLEAR REGULATORY COMMISSION
U.S. NUCLEAR REGULATORY COMMISSION  
                                    REGION IV
REGION IV  
Docket Nos.: 50-206; 50-361; 50-362; 72-41
Docket Nos.:
50-206; 50-361; 50-362; 72-41
License Nos.: DPR-13; NPF-10; NPF-15
License Nos.: DPR-13; NPF-10; NPF-15
Report No:   50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01
Report No:
Licensee:     Southern California Edison Co.
50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01
              P.O. Box 128
Licensee:
              San Clemente, California 92674
Southern California Edison Co.  
Facility:     San Onofre Nuclear Generating Station
P.O. Box 128  
Location:     San Clemente, California
San Clemente, California 92674
Dates:       June 26 - 28, 2003 (Heavy loads demonstration)
Facility:
              August 4 - 8, 2003 (Pre-operational demonstration - Initial Inspection)
San Onofre Nuclear Generating Station
              August 18 - 19, 2003 (Pre-operational demonstration - Final)
Location:
              September 10 - 15, 2003 (First cask loading - Initial Inspection)
San Clemente, California
              September 28 - October 1, 2003 (First cask loading - Final)
Dates:
Inspectors:   J. V. Everett, Team Leader, Region IV
June 26 - 28, 2003 (Heavy loads demonstration)
              R. R. Temps, Safety Inspector, NRC Spent Fuel Project Office
August 4 - 8, 2003 (Pre-operational demonstration - Initial Inspection)
              J. F. Melfi, Resident Inspector, Palo Verde Nuclear Station
August 18 - 19, 2003 (Pre-operational demonstration - Final)
              R. J. Evans, P.E., C.H.P, Senior Health Physicist, Region IV
September 10 - 15, 2003 (First cask loading - Initial Inspection)
              J. D. Parrott, Senior On-Site Representative, NRC Las Vegas Office
September 28 - October 1, 2003 (First cask loading - Final)
              M. A. Sitek, Resident Inspector, San Onofre Nuclear Station
Inspectors:
              W. C. Sifre, Reactor Inspector, Region IV
J. V. Everett, Team Leader, Region IV
              A. B. Barto, Nuclear Engineer, NRC Spent Fuel Project Office
R. R. Temps, Safety Inspector, NRC Spent Fuel Project Office
              R. V. Azua, Project Engineer, Region IV
J. F. Melfi, Resident Inspector, Palo Verde Nuclear Station
              T. W. Dexter, Security Consultant
R. J. Evans, P.E., C.H.P, Senior Health Physicist, Region IV
              E. M. Garcia, Health Physicist, Region IV
J. D. Parrott, Senior On-Site Representative, NRC Las Vegas Office
M. A. Sitek, Resident Inspector, San Onofre Nuclear Station
W. C. Sifre, Reactor Inspector, Region IV
A. B. Barto, Nuclear Engineer, NRC Spent Fuel Project Office
R. V. Azua, Project Engineer, Region IV
T. W. Dexter, Security Consultant
E. M. Garcia, Health Physicist, Region IV
Approved By: D. Blair Spitzberg, Ph.D., Chief Fuel Cycle/Decommissioning Branch
Approved By: D. Blair Spitzberg, Ph.D., Chief Fuel Cycle/Decommissioning Branch
Attachment 1: Supplemental Information
Attachment 1: Supplemental Information
Attachment 2: Inspector Notes
Attachment 2: Inspector Notes
ADAMS Entry: IR05000206-03-010; 05000361-03-010; 05000362-03-010; 072000041-03-
ADAMS Entry: IR05000206-03-010; 05000361-03-010; 05000362-03-010; 072000041-03-
              01 on 08/4/2003 - 10/01/2003; Southern California Edison Co., San Onofre
01 on 08/4/2003 - 10/01/2003; Southern California Edison Co., San Onofre
              Nuclear Generating Station; Units 1, 2, 3. ISFSI Report. No violations.
Nuclear Generating Station; Units 1, 2, 3. ISFSI Report. No violations.


                                                  -2-
-2-
                                      EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
                              San Onofre Nuclear Generating Station
San Onofre Nuclear Generating Station
          NRC Inspection Report 50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01
NRC Inspection Report 50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01
On October 3, 2003, Southern California Edison loaded the first canister of San Onofre Nuclear
On October 3, 2003, Southern California Edison loaded the first canister of San Onofre Nuclear
Generating Station (SONGS) Unit 1 spent fuel into their Independent Spent Fuel Storage
Generating Station (SONGS) Unit 1 spent fuel into their Independent Spent Fuel Storage
Installation (ISFSI). The ISFSI was located at the SONGS site adjacent to the Unit 1 reactor
Installation (ISFSI). The ISFSI was located at the SONGS site adjacent to the Unit 1 reactor
facility. The Advanced NUHOMS Horizontal Modular Storage System was selected by Southern
facility. The Advanced NUHOMS Horizontal Modular Storage System was selected by Southern
California Edison to store the SONGS spent fuel under a general license. This cask system had
California Edison to store the SONGS spent fuel under a general license. This cask system had
been approved for storage of irradiated nuclear fuel by the Nuclear Regulatory Commission (NRC)
been approved for storage of irradiated nuclear fuel by the Nuclear Regulatory Commission (NRC)
under Certificate of Compliance No. 72-1029. Transnuclear, Inc., was the cask vendor for this
under Certificate of Compliance No. 72-1029. Transnuclear, Inc., was the cask vendor for this
system.
system.
Southern California Edison planned to move all Unit 1 spent fuel to the ISFSI by the spring
Southern California Edison planned to move all Unit 1 spent fuel to the ISFSI by the spring
of 2005. This will involve moving 207 spent fuel assemblies from the Unit 1 spent fuel pool,
of 2005. This will involve moving 207 spent fuel assemblies from the Unit 1 spent fuel pool,
70 assemblies from the Unit 2 pool and 118 assemblies from the Unit 3 pool. Seventeen canisters
70 assemblies from the Unit 2 pool and 118 assemblies from the Unit 3 pool. Seventeen canisters
will be needed to hold the 395 Unit 1 spent fuel assemblies. The first five canisters to be loaded
will be needed to hold the 395 Unit 1 spent fuel assemblies. The first five canisters to be loaded
into the ISFSI would remove all the Unit 1 spent fuel from the Unit 3 pool. The ISFSI pad currently
into the ISFSI would remove all the Unit 1 spent fuel from the Unit 3 pool. The ISFSI pad currently
constructed at SONGS can accommodate 31 canisters. Each canister can hold 24 spent fuel
constructed at SONGS can accommodate 31 canisters. Each canister can hold 24 spent fuel
assemblies. The ISFSI pad will be expanded as additional space is needed and as dismantlement
assemblies. The ISFSI pad will be expanded as additional space is needed and as dismantlement
activities at Unit 1 provide more space for ISFSI construction.
activities at Unit 1 provide more space for ISFSI construction.
The inspections conducted by the NRC of Southern California Edisons dry cask storage project
The inspections conducted by the NRC of Southern California Edisons dry cask storage project
provided a comprehensive evaluation of the licensees compliance with the requirements in the
provided a comprehensive evaluation of the licensees compliance with the requirements in the
NUHOMS Certificate of Compliance No. 72-1029, Technical Specifications, Final Safety Analysis
NUHOMS Certificate of Compliance No. 72-1029, Technical Specifications, Final Safety Analysis
Report, NRCs Safety Evaluation Report and 10 CFR Part 72. The inspection consisted of a team
Report, NRCs Safety Evaluation Report and 10 CFR Part 72. The inspection consisted of a team
of eleven NRC inspectors performing inspections of various phases of activities over a period from
of eleven NRC inspectors performing inspections of various phases of activities over a period from
June 26 through October 1, 2003. Sixteen technical areas were reviewed during the inspections
June 26 through October 1, 2003. Sixteen technical areas were reviewed during the inspections
including such topical areas as fuel verification, security, radiological programs, quality assurance,
including such topical areas as fuel verification, security, radiological programs, quality assurance,
training, and heavy loads. During the inspections, the licensee conducted numerous
training, and heavy loads. During the inspections, the licensee conducted numerous
demonstrations for NRC observance related to the operations of equipment and the
demonstrations for NRC observance related to the operations of equipment and the
implementation of procedures to verify that all required aspects of the use of the NUHOMS cask
implementation of procedures to verify that all required aspects of the use of the NUHOMS cask
system at the SONGS site had been adequately incorporated into site programs and procedures.
system at the SONGS site had been adequately incorporated into site programs and procedures.  
The licensee had integrated together many of the programs for the Part 50 reactor operations and
The licensee had integrated together many of the programs for the Part 50 reactor operations and
the Part 72 ISFSI operations to allow for an efficient use of site resources.
the Part 72 ISFSI operations to allow for an efficient use of site resources.
During the various pre-operational demonstrations and during the loading of the first canister, the
During the various pre-operational demonstrations and during the loading of the first canister, the
SONGS workers demonstrated a comprehensive knowledge of the technical requirements related
SONGS workers demonstrated a comprehensive knowledge of the technical requirements related
to the loading and operations of an ISFSI and for compliance with 10 CFR Part 72. Much of this
to the loading and operations of an ISFSI and for compliance with 10 CFR Part 72. Much of this
advanced knowledge of ISFSI operations was a result of experience gained by Southern
advanced knowledge of ISFSI operations was a result of experience gained by Southern
California Edison personnel who provided manpower support to the Rancho Seco
California Edison personnel who provided manpower support to the Rancho Seco
decommissioned reactor for their ISFSI project. Rancho Seco completed the loading of
decommissioned reactor for their ISFSI project. Rancho Seco completed the loading of
21 canisters on August 2002. Southern California Edison personnel were a key part of that
21 canisters on August 2002. Southern California Edison personnel were a key part of that
successful program. The knowledge and experience gained by the Southern California Edison
successful program. The knowledge and experience gained by the Southern California Edison
personnel while at Rancho Seco was brought back and integrated into the SONGS program. This
personnel while at Rancho Seco was brought back and integrated into the SONGS program. This


                                                    -3-
-3-
was obvious during discussions and interviews of the SONGS personnel which demonstrated
was obvious during discussions and interviews of the SONGS personnel which demonstrated
actual experience and knowledge of the issues that must be addressed in order to successfully
actual experience and knowledge of the issues that must be addressed in order to successfully
load spent fuel into the ISFSI.
load spent fuel into the ISFSI.
During the loading of the first SONGS canister, the NRC provided 24-hour coverage of loading
During the loading of the first SONGS canister, the NRC provided 24-hour coverage of loading
operations for all critical tasks at the Unit 3 fuel handling building. This included fuel movement,
operations for all critical tasks at the Unit 3 fuel handling building. This included fuel movement,
heavy lifts of the loaded canister, initial radiation surveys of the loaded cask, welding of the lids,
heavy lifts of the loaded canister, initial radiation surveys of the loaded cask, welding of the lids,
vacuum drying and helium backfill of the canister. Workers were knowledgeable of their assigned
vacuum drying and helium backfill of the canister. Workers were knowledgeable of their assigned
tasks and had been well trained. Problems and issues were quickly identified and effectively
tasks and had been well trained. Problems and issues were quickly identified and effectively
resolved. Shift supervision provided good oversight of work activities and workers always knew
resolved. Shift supervision provided good oversight of work activities and workers always knew
who was in charge. Procedures were closely followed and a good questioning attitude was
who was in charge. Procedures were closely followed and a good questioning attitude was
demonstrated by all employees. There was good communications between the workers. Overall,
demonstrated by all employees. There was good communications between the workers. Overall,
the licensees staff was well trained and highly motivated to perform work safely and in compliance
the licensees staff was well trained and highly motivated to perform work safely and in compliance
with the procedural requirements. The management team responsible for the ISFSI project had
with the procedural requirements. The management team responsible for the ISFSI project had
worked hard to develop and implement a comprehensive program that would provide for the safe
worked hard to develop and implement a comprehensive program that would provide for the safe
operations of moving spent fuel at the SONGS site.
operations of moving spent fuel at the SONGS site.
Details related to the 16 technical areas reviewed during this inspection are provided as
Details related to the 16 technical areas reviewed during this inspection are provided as
Attachment 2 to this inspection report. The following provides a summary of the findings of this
Attachment 2 to this inspection report. The following provides a summary of the findings of this
inspection.
inspection.
Vacuum Drying, Helium Backfill and Helium Testing
Vacuum Drying, Helium Backfill and Helium Testing
!       Vacuum drying time limits established in Technical Specification 3.1.1 had been
!
        incorporated into the licensees procedures. Canisters with a heat load greater than
Vacuum drying time limits established in Technical Specification 3.1.1 had been
        12 kW were required to be vacuum dried within a specific time frame. The licensees
incorporated into the licensees procedures. Canisters with a heat load greater than
        procedure included provisions for establishing a helium environment in the canister or re-
12 kW were required to be vacuum dried within a specific time frame. The licensees
        flooding the canister, as required by the technical specification, if the time limit was not
procedure included provisions for establishing a helium environment in the canister or re-
        met.
flooding the canister, as required by the technical specification, if the time limit was not
!       The licensee had implemented a stepped vacuum drying process consistent with the
met.  
        requirements in Technical Specification 3.1.1. This stepped process of lowering the
!
        pressure in the canister to certain predetermined levels and holding at that level for a
The licensee had implemented a stepped vacuum drying process consistent with the
        period of time was intended to reduce the likelihood of ice blockage in the system lines.
requirements in Technical Specification 3.1.1. This stepped process of lowering the
        The final vacuum drying pressure requirement for the canister was 3 torr. The licensees
pressure in the canister to certain predetermined levels and holding at that level for a
        procedures specified a value of 2.8 torr to account for instrument error and to provide an
period of time was intended to reduce the likelihood of ice blockage in the system lines.  
        extra margin for compliance.
The final vacuum drying pressure requirement for the canister was 3 torr. The licensees
!       Helium backfill pressure requirements established in Technical Specification 3.1.2 had
procedures specified a value of 2.8 torr to account for instrument error and to provide an
        been incorporated into the licensees procedures. Provisions for documenting the final
extra margin for compliance.
        helium backfill pressure reading was provided in the procedure, including independent
!
        verification and sign-off by quality control personnel.
Helium backfill pressure requirements established in Technical Specification 3.1.2 had
!       Helium leak rate testing of the inner lid weld and the vent/siphon port cover welds required
been incorporated into the licensees procedures. Provisions for documenting the final
        by Technical Specification 3.1.3 had been incorporated into the licensees procedures.
helium backfill pressure reading was provided in the procedure, including independent
        Procedural requirements included specifications for the helium to be $99 percent pure and
verification and sign-off by quality control personnel.
!
Helium leak rate testing of the inner lid weld and the vent/siphon port cover welds required
by Technical Specification 3.1.3 had been incorporated into the licensees procedures.  
Procedural requirements included specifications for the helium to be $99 percent pure and


                                                -4-
-4-
      the leak rate to be #10-7 standard cubic centimeters/second. Procedures also required
the leak rate to be #10-7 standard cubic centimeters/second. Procedures also required
      helium leak test personnel to be qualified to the standards in SNT-TC-1 Personnel
helium leak test personnel to be qualified to the standards in SNT-TC-1 Personnel
      Qualification and Certification of Nondestructive Testing.
Qualification and Certification of Nondestructive Testing.
Emergency Planning
Emergency Planning
!     Emergency planning provisions for the ISFSI had been incorporated into the site-wide
!
      emergency plan. This included specific emergency action levels for fires, loss of canister
Emergency planning provisions for the ISFSI had been incorporated into the site-wide
      integrity and security events.
emergency plan. This included specific emergency action levels for fires, loss of canister
!     The ISFSI design provided for accessability by emergency personnel and vehicles. The
integrity and security events.
      licensee maintained their own site fire and medical response capability. Offsite fire,
!
      security and medical support organizations were available to augment the site emergency
The ISFSI design provided for accessability by emergency personnel and vehicles. The
      organization.
licensee maintained their own site fire and medical response capability. Offsite fire,
security and medical support organizations were available to augment the site emergency
organization.
Fire Protection
Fire Protection
!     The ISFSI had been incorporated into the San Onofre Updated Fire Hazards Analysis.
!
      Administrative controls were established to limit the quantity of combustible and flammable
The ISFSI had been incorporated into the San Onofre Updated Fire Hazards Analysis.  
      liquids around the ISFSI and near the transport path during movement of the canister.
Administrative controls were established to limit the quantity of combustible and flammable
!     Analysis had been completed to evaluate the effect on the ISFSI of site specific explosive
liquids around the ISFSI and near the transport path during movement of the canister.
      hazards and to confirm that the design of the ISFSI was adequate for the postulated
!
      external pressure levels that could result from an explosion.
Analysis had been completed to evaluate the effect on the ISFSI of site specific explosive
hazards and to confirm that the design of the ISFSI was adequate for the postulated
external pressure levels that could result from an explosion.
Fuel Verification
Fuel Verification
!     The SONGS Unit 1 spent fuel was stored in four locations: 270 assemblies at the General
!
      Electric spent fuel storage pool located in Morris, Illinois; 207 assemblies in the SONGS
The SONGS Unit 1 spent fuel was stored in four locations: 270 assemblies at the General
      Unit 1 spent fuel pool; 70 assemblies in the SONGS Unit 2 spent fuel pool; and 118
Electric spent fuel storage pool located in Morris, Illinois; 207 assemblies in the SONGS
      assemblies in the SONGS Unit 3 spent fuel pool. The first loading campaign will load the
Unit 1 spent fuel pool; 70 assemblies in the SONGS Unit 2 spent fuel pool; and 118
      Unit 1 spent fuel stored in the Unit 3 spent fuel pool. This will require five canisters.
assemblies in the SONGS Unit 3 spent fuel pool. The first loading campaign will load the
!     The requirements in Certificate of Compliance No. 1029 for the type of fuel that can be
Unit 1 spent fuel stored in the Unit 3 spent fuel pool. This will require five canisters.
      stored in the Advanced NUHOMS 24PT1 canisters was evaluated against the SONGS
!
      Unit 1 spent fuel planned for loading in the first five canisters. Criteria included type of
The requirements in Certificate of Compliance No. 1029 for the type of fuel that can be
      fuel, cladding, decay heat, burn-up, neutron/gamma source strength, cooling time and
stored in the Advanced NUHOMS 24PT1 canisters was evaluated against the SONGS
      enrichment. All spent fuel assemblies met the technical specification requirements.
Unit 1 spent fuel planned for loading in the first five canisters. Criteria included type of
!     Twenty-seven Unit 1 fuel assemblies had been identified as damaged. Of these, four
fuel, cladding, decay heat, burn-up, neutron/gamma source strength, cooling time and
      were in the Unit 3 spent fuel pool and will be included in the first loading campaign of five
enrichment. All spent fuel assemblies met the technical specification requirements.
      canisters. Damaged fuel assembles were required to be placed in special failed fuel cans
!
      inside the canisters. Criteria used by the licensee for identifying which fuel assemblies
Twenty-seven Unit 1 fuel assemblies had been identified as damaged. Of these, four
      were damaged was consistent with NRC guidance.
were in the Unit 3 spent fuel pool and will be included in the first loading campaign of five
canisters. Damaged fuel assembles were required to be placed in special failed fuel cans
inside the canisters. Criteria used by the licensee for identifying which fuel assemblies
were damaged was consistent with NRC guidance.


                                                -5-
-5-
!     The licensee had established provisions for independent verification of the correct loading
!
      of the canister. This included videotaping the location of the spent fuel after loading in the
The licensee had established provisions for independent verification of the correct loading
      canister.
of the canister. This included videotaping the location of the spent fuel after loading in the
!     Because the NUHOMS canisters were inserted into the concrete storage modules
canister.
      horizontally, special center of gravity considerations for the canisters were necessary to
!
      prevent rotation of the canister during insertion into the concrete storage module.
Because the NUHOMS canisters were inserted into the concrete storage modules
      Technical specifications required the center of gravity of the loaded canister to be within
horizontally, special center of gravity considerations for the canisters were necessary to
      0.1" of the canisters radial center of gravity. Licensee calculations for the first five
prevent rotation of the canister during insertion into the concrete storage module.  
      canisters demonstrated compliance with this limit. The largest deviation from the radial
Technical specifications required the center of gravity of the loaded canister to be within
      center of gravity was 0.0042".
0.1" of the canisters radial center of gravity. Licensee calculations for the first five
canisters demonstrated compliance with this limit. The largest deviation from the radial
center of gravity was 0.0042".
Compliance with 10 CFR Part 72 General License Requirements
Compliance with 10 CFR Part 72 General License Requirements
!     The licensee evaluated the bounding environmental conditions specified in the NUHOMS
!
      Final Safety Analysis Report and Certificate of Compliance No. 1029 technical
The licensee evaluated the bounding environmental conditions specified in the NUHOMS
      specifications against the conditions at the SONGS site. This included: tornados/high
Final Safety Analysis Report and Certificate of Compliance No. 1029 technical
      winds, flood, seismic events, snow/ice loading, tsunami, lightning, burial under debris,
specifications against the conditions at the SONGS site. This included: tornados/high
      normal and abnormal temperatures, and fires/explosions. The site environmental
winds, flood, seismic events, snow/ice loading, tsunami, lightning, burial under debris,
      conditions at the SONGS ISFSI were bounded by the NUHOMS cask design parameters.
normal and abnormal temperatures, and fires/explosions. The site environmental
!     Radiation levels at the ISFSI were calculated for workers during loading operations and
conditions at the SONGS ISFSI were bounded by the NUHOMS cask design parameters.
      routine surveillance activities. Doses were calculated for the controlled area boundary.
!
      Doses at the controlled area boundary were projected to be 1 mrem/year, well below the
Radiation levels at the ISFSI were calculated for workers during loading operations and
      10 CFR 72.104 limit of 25 mrem/year. Projected worker doses to conduct the daily visual
routine surveillance activities. Doses were calculated for the controlled area boundary.  
      inspection were 172 millirem/year. Weekly radiation surveys of the ISFSI could add
Doses at the controlled area boundary were projected to be 1 mrem/year, well below the
      49 millirem/year. A conservative estimate for loading a cask was determined to be
10 CFR 72.104 limit of 25 mrem/year. Projected worker doses to conduct the daily visual
      3117 millirem per canister loading.
inspection were 172 millirem/year. Weekly radiation surveys of the ISFSI could add
!     The licensee performed an evaluation of the site programs that could be impacted by the
49 millirem/year. A conservative estimate for loading a cask was determined to be
      addition of an ISFSI. The evaluation included the radiation protection program, emergency
3117 millirem per canister loading.
      planning program, quality assurance program, training program and the reactor technical
!
      specifications and Part 50 license. Revisions to the programs to incorporate the ISFSI
The licensee performed an evaluation of the site programs that could be impacted by the
      were identified and implemented.
addition of an ISFSI. The evaluation included the radiation protection program, emergency
!     The NUHOMS Certificate of Compliance and Final Safety Analysis Report had been
planning program, quality assurance program, training program and the reactor technical
      reviewed by the licensee to verify that the design basis for the NUHOMS cask system and
specifications and Part 50 license. Revisions to the programs to incorporate the ISFSI
      the conditions and requirements in the Certificate of Compliance and Final Safety Analysis
were identified and implemented.
      Report were met.
!
The NUHOMS Certificate of Compliance and Final Safety Analysis Report had been
reviewed by the licensee to verify that the design basis for the NUHOMS cask system and
the conditions and requirements in the Certificate of Compliance and Final Safety Analysis
Report were met.
Heavy Loads
Heavy Loads
!     The licensee had incorporated the special requirements related to the ISFSI project into
!
      the site heavy loads programs and procedures. Crane operators interviewed during the
The licensee had incorporated the special requirements related to the ISFSI project into
      ISFSI inspections were knowledgeable of the special handling requirements related to the
the site heavy loads programs and procedures. Crane operators interviewed during the
      heavy spent fuel casks.
ISFSI inspections were knowledgeable of the special handling requirements related to the
heavy spent fuel casks.


                                                  -6-
-6-
!     Special lifting device height limits and temperature restrictions during movement of the
!
      casks had been incorporated into the licensees procedures consistent with the
Special lifting device height limits and temperature restrictions during movement of the
      requirements in the Certificate of Compliance. This included the requirement to perform
casks had been incorporated into the licensees procedures consistent with the
      an inspection of the cask for damage after any drop of 15" or higher.
requirements in the Certificate of Compliance. This included the requirement to perform
!     The maximum weight of the loaded transfer cask had been determined by the licensee to
an inspection of the cask for damage after any drop of 15" or higher.
      verify the adequacy of the lift capability of the cranes planned for use in moving the spent
!
      fuel. A loaded cask being removed from the spent fuel pool represented the maximum
The maximum weight of the loaded transfer cask had been determined by the licensee to
      weight to be lifted and exceeded the lifting capacity of the current Unit 1 crane. The
verify the adequacy of the lift capability of the cranes planned for use in moving the spent
      licensee had purchased new single failure proof cranes for installation and use during the
fuel. A loaded cask being removed from the spent fuel pool represented the maximum
      cask loading operations. The Unit 3 crane was rated at 125 tons. The Unit 1 crane would
weight to be lifted and exceeded the lifting capacity of the current Unit 1 crane. The
      be up-rated from 100 tons to 105 tons to account for the estimated 104.1 ton weight of the
licensee had purchased new single failure proof cranes for installation and use during the
      loaded cask.
cask loading operations. The Unit 3 crane was rated at 125 tons. The Unit 1 crane would
!     A safe loads path had been identified and analyzed for moving the spent fuel from the
be up-rated from 100 tons to 105 tons to account for the estimated 104.1 ton weight of the
      spent fuel pool to the ISFSI. Provisions were established in procedures and through the
loaded cask.
      use of limit switches to prevent the crane from moving the loaded cask outside the
!
      boundaries of the safe load path while in the fuel building. Calculations were performed
A safe loads path had been identified and analyzed for moving the spent fuel from the
      for the roadway between the plant and the ISFSI to verify that the path was structurally
spent fuel pool to the ISFSI. Provisions were established in procedures and through the
      capable of handling the weight of the loaded transfer cask and trailer.
use of limit switches to prevent the crane from moving the loaded cask outside the
!     The licensees heavy loads procedural requirements related to the transfer cask trunnions
boundaries of the safe load path while in the fuel building. Calculations were performed
      and the slings used for lifting the canister lid were verified against industry standards and
for the roadway between the plant and the ISFSI to verify that the path was structurally
      manufacturer requirements for load tests, safety margins and inspection/maintenance.
capable of handling the weight of the loaded transfer cask and trailer.
!     The adequacy of the transport trailer for the expected weight of a loaded canister and the
!
      ability of the transport trailer to safely secure and move the cask to the ISFSI was verified.
The licensees heavy loads procedural requirements related to the transfer cask trunnions
and the slings used for lifting the canister lid were verified against industry standards and
manufacturer requirements for load tests, safety margins and inspection/maintenance.
!
The adequacy of the transport trailer for the expected weight of a loaded canister and the
ability of the transport trailer to safely secure and move the cask to the ISFSI was verified.
Pad/Storage Modules
Pad/Storage Modules
!     Requirements in the Final Safety Analysis Report related to the placement of the storage
!
      modules on the ISFSI pad and the module-to-module connections required for the high
Requirements in the Final Safety Analysis Report related to the placement of the storage
      seismic conditions at the SONGS site were being implemented.
modules on the ISFSI pad and the module-to-module connections required for the high
!     The concrete storage module thermal monitoring program had been incorporated into
seismic conditions at the SONGS site were being implemented.
      procedures. This included the daily monitoring of the storage module temperature and the
!
      daily verification that the air inlets and outlets were free from debris.
The concrete storage module thermal monitoring program had been incorporated into
!     The thickness requirements for the concrete storage module roof and shield walls to
procedures. This included the daily monitoring of the storage module temperature and the
      ensure radiological levels would be below regulatory limits were verified by direct
daily verification that the air inlets and outlets were free from debris.
      observation of the storage modules under construction and a review of the design
!
      drawings.
The thickness requirements for the concrete storage module roof and shield walls to
!     The seismic design of the ISFSI pad to meet the potential earthquake intensity at the
ensure radiological levels would be below regulatory limits were verified by direct
      SONGS site and to address liquefaction of the soil under the pad was inspected by the
observation of the storage modules under construction and a review of the design
drawings.
!
The seismic design of the ISFSI pad to meet the potential earthquake intensity at the
SONGS site and to address liquefaction of the soil under the pad was inspected by the


                                                -7-
-7-
      NRC on April 9, 2002, and documented in Inspection Report 50-206/02-07;72-41/02-01
NRC on April 9, 2002, and documented in Inspection Report 50-206/02-07;72-41/02-01
      issued May 21, 2002 (NRC Adams Document ML021410532).
issued May 21, 2002 (NRC Adams Document ML021410532).
Pre-Operational Testing
Pre-Operational Testing
!     The licensee successfully completed all the required pre-operational test requirements
!
      specified by the Certificate of Compliance. This include the loading, welding, drying, and
The licensee successfully completed all the required pre-operational test requirements
      backfilling of a canister and the unloading of a sealed canister. A weighted canister was
specified by the Certificate of Compliance. This include the loading, welding, drying, and
      used to demonstrate heavy load activities, transport between the Unit 3 facility and the
backfilling of a canister and the unloading of a sealed canister. A weighted canister was
      ISFSI and insertion/removal of a canister into the concrete storage module.
used to demonstrate heavy load activities, transport between the Unit 3 facility and the
ISFSI and insertion/removal of a canister into the concrete storage module.
Procedures and Technical Specification Requirements
Procedures and Technical Specification Requirements
!     The licensee had developed the required operating procedures and programs required by
!
      the Certificate of Compliance.
The licensee had developed the required operating procedures and programs required by
!     The adequacy of the level of detail in the procedures was verified by reviewing
the Certificate of Compliance.
      requirements in the Final Safety Analysis Report related to handling the cask at the spent
!
      fuel pool. All requirements reviewed had been incorporated as operational steps in the
The adequacy of the level of detail in the procedures was verified by reviewing
      licensees procedures.
requirements in the Final Safety Analysis Report related to handling the cask at the spent
fuel pool. All requirements reviewed had been incorporated as operational steps in the
licensees procedures.
Quality Assurance
Quality Assurance
!     The licensee had implemented their approved reactor facility Part 50 quality assurance
!
      program for the activities associated with the ISFSI. Effective implementation of the
The licensee had implemented their approved reactor facility Part 50 quality assurance
      program was observed for all phases of ISFSI activities including procurement, control of
program for the activities associated with the ISFSI. Effective implementation of the
      measuring equipment, corrective actions, design control, receipt inspections, storage and
program was observed for all phases of ISFSI activities including procurement, control of
      audits.
measuring equipment, corrective actions, design control, receipt inspections, storage and
!     Southern California Edison was constructing their canisters onsite as a fabricator to
audits.
      Transnuclear, Inc. An inspection conducted by the NRCs Spent Fuel Project Office on
!
      March 3-6, 2003, and documented in Inspection Report 72-1029/2003201 issued March 6,
Southern California Edison was constructing their canisters onsite as a fabricator to
      2003, found all work activities were being properly controlled under the Southern
Transnuclear, Inc. An inspection conducted by the NRCs Spent Fuel Project Office on
      California Edison quality assurance program (NRC Adams Document ML030940163).
March 3-6, 2003, and documented in Inspection Report 72-1029/2003201 issued March 6,
!     The licensees quality assurance organization had implemented a comprehensive quality
2003, found all work activities were being properly controlled under the Southern
      assurance audit and inspection program that was responsive to applying additional
California Edison quality assurance program (NRC Adams Document ML030940163).
      oversight to selected work activities where problems were being identified. This was most
!
      evident in the decision to place onsite quality assurance inspectors at one of the vendors
The licensees quality assurance organization had implemented a comprehensive quality
      to ensure the quality of the concrete storage modules.
assurance audit and inspection program that was responsive to applying additional
oversight to selected work activities where problems were being identified. This was most
evident in the decision to place onsite quality assurance inspectors at one of the vendors
to ensure the quality of the concrete storage modules.
Radiation Protection
Radiation Protection
!     Requirements for radiological and contamination surveys described in the Final Safety
!
      Analysis Report had been incorporated into the licensees health physics program for the
Requirements for radiological and contamination surveys described in the Final Safety
Analysis Report had been incorporated into the licensees health physics program for the


                                                -8-
-8-
      loading of the casks. This included special precautions related to potential high dose rate
loading of the casks. This included special precautions related to potential high dose rate
      work activities.
work activities.
!     Calculations performed by the licensee to evaluate the potential radiological doses during
!
      normal operations at the ISFSI and during an accident demonstrated compliance with the
Calculations performed by the licensee to evaluate the potential radiological doses during
      limits specified in 10 CFR 72.104 and 10 CFR 72.106.
normal operations at the ISFSI and during an accident demonstrated compliance with the
!     The licensee had identified the reactor Part 50 exclusion area as the controlled area for
limits specified in 10 CFR 72.104 and 10 CFR 72.106.
      the ISFSI. The distance from the ISFSI to the exclusion area boundary met the required
!
      minimum distance for a controlled area around an ISFSI specified in 10 CFR 72.106.
The licensee had identified the reactor Part 50 exclusion area as the controlled area for
      Southern California Edison was authorized, through a signed easement, to remove
the ISFSI. The distance from the ISFSI to the exclusion area boundary met the required
      personnel from the exclusion area in the event of an emergency.
minimum distance for a controlled area around an ISFSI specified in 10 CFR 72.106.  
!     The licensee had determined a dose conversion factor for neutron doses to workers to
Southern California Edison was authorized, through a signed easement, to remove
      account for the neutron spectrum expected with the loaded canisters.
personnel from the exclusion area in the event of an emergency.
!     Environmental monitoring for the ISFSI had been incorporated into the existing reactor
!
      environmental monitoring program. Additional thermoluminescent dosimeters had been
The licensee had determined a dose conversion factor for neutron doses to workers to
      placed around the ISFSI to monitor the increase in radiation levels expected due to the
account for the neutron spectrum expected with the loaded canisters.
      storage of the spent fuel. Dosimeters had been placed in service in 2001 and had been
!
      used to collect background data that could be compared with the ongoing monitoring after
Environmental monitoring for the ISFSI had been incorporated into the existing reactor
      spent fuel was placed in the ISFSI to determine the level of increase in radiation levels.
environmental monitoring program. Additional thermoluminescent dosimeters had been
placed around the ISFSI to monitor the increase in radiation levels expected due to the
storage of the spent fuel. Dosimeters had been placed in service in 2001 and had been
used to collect background data that could be compared with the ongoing monitoring after
spent fuel was placed in the ISFSI to determine the level of increase in radiation levels.
Records
Records
!     A records system had been established by the licensee under their reactor Part 50 quality
!
      assurance program. Records required for retention by 10 CFR 72.174, 10 CFR 72.212,
A records system had been established by the licensee under their reactor Part 50 quality
      10 CFR 72.234 and the Final Safety Analysis Report had been identified in the licensees
assurance program. Records required for retention by 10 CFR 72.174, 10 CFR 72.212,
      program as required records for retention.
10 CFR 72.234 and the Final Safety Analysis Report had been identified in the licensees
!     An optical disk system was being used for permanent storage of the records. The quality
program as required records for retention.
      assurance plan required that ISFSI related records be retained for the duration of the
!
      license or certificate of compliance.
An optical disk system was being used for permanent storage of the records. The quality
!     The required 90-day notification prior to loading the first cask had been made to the NRC
assurance plan required that ISFSI related records be retained for the duration of the
      on May 5, 2003. The requirement to provide notice to the NRC within 30 days of use of a
license or certificate of compliance.
      cask had been incorporated into the appropriate procedure.
!
The required 90-day notification prior to loading the first cask had been made to the NRC
on May 5, 2003. The requirement to provide notice to the NRC within 30 days of use of a
cask had been incorporated into the appropriate procedure.
Safety Reviews
Safety Reviews
!     Changes to the site related to the construction and operation of the ISFSI were being
!
      evaluated in accordance with 10 CFR 72.48 and 10 CFR 50.59 requirements. No issues
Changes to the site related to the construction and operation of the ISFSI were being
      were identified during the review of selected safety screenings.
evaluated in accordance with 10 CFR 72.48 and 10 CFR 50.59 requirements. No issues
were identified during the review of selected safety screenings.


                                                -9-
-9-
Security
Security
!     Security for the ISFSI had been integrated into the overall site security program. The
!
      security plan and procedures had been revised to incorporate specific provisions for
Security for the ISFSI had been integrated into the overall site security program. The
      responding to a security threat at the ISFSI. Arrangements had been established to obtain
security plan and procedures had been revised to incorporate specific provisions for
      support from local law enforcement agencies during a security event.
responding to a security threat at the ISFSI. Arrangements had been established to obtain
!     Security force personnel were trained on security requirements for the ISFSI including the
support from local law enforcement agencies during a security event.
      implementation of access controls, key controls and compensatory actions.
!
!     Physical security systems had been installed and were operational. This included the
Security force personnel were trained on security requirements for the ISFSI including the
      protected area fence, lighting systems, intrusion detection systems and backup power.
implementation of access controls, key controls and compensatory actions.
!     Arrangements had been made for a moving protected area around the cask during
!
      transport from Unit 3 to the ISFSI.
Physical security systems had been installed and were operational. This included the
protected area fence, lighting systems, intrusion detection systems and backup power.
!
Arrangements had been made for a moving protected area around the cask during
transport from Unit 3 to the ISFSI.
Training
Training
!     The licensee had implemented a training program for workers assigned to the ISFSI that
!
      incorporated the topics listed in the technical specifications and provided for
The licensee had implemented a training program for workers assigned to the ISFSI that
      documentation of completion of training and job task qualification.
incorporated the topics listed in the technical specifications and provided for
!     Specific training needs had been identified and incorporated into training for operations,
documentation of completion of training and job task qualification.
      maintenance and health physics personnel as required by the Final Safety Analysis
!
      Report.
Specific training needs had been identified and incorporated into training for operations,
!     A computerized training records system had been established by the licensee to track
maintenance and health physics personnel as required by the Final Safety Analysis
      completion of training by individuals.
Report.
!
A computerized training records system had been established by the licensee to track
completion of training by individuals.
Welding/Nondestructive Testing
Welding/Nondestructive Testing
!     Requirements for hydrogen monitoring during welding of the inner cask lid had been
!
      incorporated into the procedures. The alarm set point had been established at 50 percent
Requirements for hydrogen monitoring during welding of the inner cask lid had been
      of a lower explosive limit for hydrogen. During welding of the inner lid welds, hydrogen
incorporated into the procedures. The alarm set point had been established at 50 percent
      levels were measured from 3 percent to 8.4 percent of the lower explosive limit.
of a lower explosive limit for hydrogen. During welding of the inner lid welds, hydrogen
!     The licensee was performing the required dye penetrant examinations of welds on the
levels were measured from 3 percent to 8.4 percent of the lower explosive limit.
      canister in accordance with the Final Safety Analysis Report. Dye penetrant examination
!
      procedures had been developed for both normal temperatures and for the higher
The licensee was performing the required dye penetrant examinations of welds on the
      temperatures that could be encountered with the hotter casks.
canister in accordance with the Final Safety Analysis Report. Dye penetrant examination
!     Nondestructive examination requirements for welds were adequately specified in
procedures had been developed for both normal temperatures and for the higher
      procedures and on drawings.
temperatures that could be encountered with the hotter casks.
!     Nondestructive examination personnel were qualified to the requirements in SNT-TC-1A
!
      for performing weld examinations of the type required on the canisters.
Nondestructive examination requirements for welds were adequately specified in
procedures and on drawings.
!
Nondestructive examination personnel were qualified to the requirements in SNT-TC-1A
for performing weld examinations of the type required on the canisters.


                                                -10-
-10-
Exit Meetings
Exit Meetings
The inspectors presented the inspection results to members of licensee management at the
The inspectors presented the inspection results to members of licensee management at the
conclusion of the various key stages of the inspection on August 8, August 19 and October 1,
conclusion of the various key stages of the inspection on August 8, August 19 and October 1,
2003. The licensee acknowledged the findings presented. The licensee did not identify as
2003. The licensee acknowledged the findings presented. The licensee did not identify as
proprietary any information provided to, or reviewed by, the inspectors that had been incorporated
proprietary any information provided to, or reviewed by, the inspectors that had been incorporated
into the inspection effort.
into the inspection effort.


                                        ATTACHMENT 1
ATTACHMENT 1
                                SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
                            PARTIAL LIST OF PERSONS CONTACTED
PARTIAL LIST OF PERSONS CONTACTED
Licensee
Licensee
J. Agosti, Lead Auditor, Procurement Quality
J. Agosti, Lead Auditor, Procurement Quality
Line 552: Line 656:
D. Pilmer, Manager, Dry Cask Fuel Storage Licensing
D. Pilmer, Manager, Dry Cask Fuel Storage Licensing


                                                -2-
-2-
D. Ripley, Manager, Maintenance Training
D. Ripley, Manager, Maintenance Training
M. Russell, Technical Specialist
M. Russell, Technical Specialist
Line 572: Line 676:
Transnuclear, Inc.
Transnuclear, Inc.
U. Farradj, Project Manager
U. Farradj, Project Manager
                              INSPECTION PROCEDURES USED
INSPECTION PROCEDURES USED
60854           Pre-operational Testing of an ISFSI
60854
60855           Operations of an ISFSI
Pre-operational Testing of an ISFSI
60856           Review of 10 CFR 72.212(b) Evaluations
60855
60857           Review of 10 CFR 72.48 Evaluations
Operations of an ISFSI
81001           ISFSI Security
60856
                                  ITEMS OPENED AND CLOSED
Review of 10 CFR 72.212(b) Evaluations
60857
Review of 10 CFR 72.48 Evaluations
81001
ISFSI Security
ITEMS OPENED AND CLOSED
Opened
Opened
None
None
Line 586: Line 695:
None
None


                                            -3-
-3-
                                LIST OF ACRONYMS USED
LIST OF ACRONYMS USED
ALARA     as low as reasonably achievable
ALARA
ANSI       American National Standards Institute, Inc
as low as reasonably achievable
CFR       code of federal regulations
ANSI
DAC       derived air concentration
American National Standards Institute, Inc
DSC       dry shielded canister
CFR
FSAR       final safety analysis report
code of federal regulations
GWd/MTU   gigawatt days/metric ton uranium
DAC
ISFSI     independent spent fuel storage installation
derived air concentration
kW         kilowatt
DSC
MOX       mixed-oxide fuel
dry shielded canister
NDE       nondestructive examinations
FSAR
NRC       Nuclear Regulatory Commission
final safety analysis report
psi       pounds/in2
GWd/MTU
psig       pounds/in2 (gauge)
gigawatt days/metric ton uranium
QA         quality assurance
ISFSI
SAR       safety analysis report (same as final safety analysis report)
independent spent fuel storage installation
SNT-TC     Society of Nondestructive Testing-Technical Council
kW
SONGS     San Onofre Generating Station
kilowatt
std-cc/sec standard cubic centimeters/second
MOX
Tech Specs technical specifications
mixed-oxide fuel
UFSAR     updated final safety analysis report
NDE
nondestructive examinations
NRC
Nuclear Regulatory Commission
psi
pounds/in2
psig
pounds/in2 (gauge)
QA
quality assurance
SAR
safety analysis report (same as final safety analysis report)
SNT-TC
Society of Nondestructive Testing-Technical Council
SONGS
San Onofre Generating Station
std-cc/sec
standard cubic centimeters/second
Tech Specs
technical specifications
UFSAR
updated final safety analysis report
}}
}}

Latest revision as of 05:51, 16 January 2025

IR 05000206-03-010; 05000361-03-010; 05000362-03-010; 07200041-03-001; on 08/4/2003 - 10/01/2003; Southern California Edison Co., San Onofre Nuclear Generating Station; Units 1, 2, 3. ISFSI Report. No Violations. Cover Letter, 01/06/2004
ML040060764
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/06/2004
From: Spitzberg D
NRC/RGN-IV/DNMS/FCDB
To: Ray H
Southern California Edison Co
References
-RFPFR IR-03-001, IR-03-010
Download: ML040060764 (17)


See also: IR 05000206/2003010

Text

January 6, 2004

Mr. Harold B. Ray, Executive Vice President

Southern California Edison Co.

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, California 92674-0128

SUBJECT:

NRC INSPECTION REPORT 50-206/03-10; 50-361/03-10; 50-362/03-10;

72-41/03-01 FOR THE PRE-OPERATIONAL TESTING AND FIRST CANISTER

LOADING AT THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Dear Mr. Ray:

NRC inspections were conducted between June 26 and October 1, 2003, at your San Onofre

nuclear generating station to evaluate the dry cask storage activities for your Independent Spent

Fuel Storage Installation (ISFSI). These inspections included observation of activities associated

with your pre-operational testing program and the loading of your first canister. The inspections

were conducted to confirm compliance of your program and activities with the requirements

specified in the license, technical specifications, Final Safety Analysis Report, the NRCs Safety

Evaluation Report and 10 CFR Part 72. The enclosed report presents the results of these

inspections. The inspections found that activities were being performed in accordance with

procedural and regulatory requirements. No violations of NRC regulations were identified.

In accordance with 10 CFR 2.790 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. Vincent Everett, Senior Health Physicist, at (817) 860-8198.

Sincerely,

/RA/

D. Blair Spitzberg, Ph.D., Chief

Fuel Cycle and Decommissioning Branch

Docket Nos.: 50-206; 50-361; 50-362; 72-41

License Nos.: DPR-13; NPF-10; NPF-15

Southern California Edison Company

-2-

Enclosure:

NRC Inspection Report

50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01

cc w/enclosure:

Dwight E. Nunn, Vice President

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, California 92674-0128

Michael R. Olson

San Onofre Liaison

San Diego Gas & Electric Company

P.O. Box 1831

San Diego, California 92112-4150

Mayor

City of San Clemente

100 Avenida Presidio

San Clemente, California 92672

Chairman, Board of Supervisors

County of San Diego

1600 Pacific Highway, Room 335

San Diego, California 92101

Ed Bailey, Radiation Program Director

Radiologic Health Branch

State Department of Health Services

P.O. Box 942732 (MS 178)

Sacramento, California 94327-7320

David Spath, Chief

Division of Drinking Water and

Environmental Management

P.O. Box 942732

Sacramento, California 94234-7320

James D. Boyd, Commissioner

California Energy Commission

1516 Ninth Street (MS 34)

Sacramento, California 95814

Southern California Edison Company

-3-

Douglas K. Porter, Esq.

Southern California Edison Company

2244 Walnut Grove Avenue

Rosemead, California 91770

Gary L. Nolff

Power Projects/Contracts Manager

Riverside Public Utilities

2911 Adams Street

Riverside, California 92504

Eileen M. Teichert, Esq.

Supervising Deputy City Attorney

City of Riverside

3900 Main Street

Riverside, California 92522

Dr. Raymond Waldo

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, California 92674-0128

A. Edward Scherer

Southern California Edison

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, California 92674-0128

Joseph J. Wambold, Vice President

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, California 92764-0128

Southern California Edison Company

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bcc w/enclosure (via ADAMS e-mail distribution):

EECollins

DBSpitzberg

KMKennedy

SCOConnor

ERZiegler

CCOsterholtz

MASitek

RRTemps

ABBarto

JFMelfi

JDParrott

RJEvans

WCSifre

RVAzua

TWDexter

EMGarcia

FCDB

NBHolbrook

RIV Materials Docket Files - 5th Floor

ADAMS: :Yes

9No Initials: JVE

Publicly Available 9Non-Publicly Available

9Sensitive

Non-Sensitive

DOCUMENT NAME: s:\\dnms\\fcdb\\jve\\So1-2003-010 jve.wpd final r:\\_so1\\So1-2003-10.wpd

RIV:DNMS:FCDB

FCDB

FCDB

FCDB

JVEverett

EMGarcia

RJEvans

TWDexter

/RA/

/RA JVEverett via E/

/RA JVEverett via E/

/RA JVEverett via E/

12/18/03

12/22/03

12/18/03

12/18/03

NMSS:DWM:HLWB

NMSS:SFPO

DRP:PBC

DRP:PBC

JDParrott

RRTemps

JFMelfi

MASitek

/RA JVEverett via E/

/RA JVEverett via E/

/RA JVEverett via E/

/RA JVEverett via E/

12/16/03

12/17/03

12/15/03

1/6/04

DRP:PBC

DRS:EMB

NMSS:SFPO

C:FCDB

RVAzua

WCSifre

ABBarto

DBSpitzberg

/RA JVEverett via E/

/RA JVEverett via E/

/RA JVEverett via E/

/RA/

12/29/03

12/18/03

12/30/03

1/6/04

OFFICIAL RECORD COPY

T=Telephone E=E-mail F=Fax

ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.:

50-206; 50-361; 50-362; 72-41

License Nos.: DPR-13; NPF-10; NPF-15

Report No:

50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01

Licensee:

Southern California Edison Co.

P.O. Box 128

San Clemente, California 92674

Facility:

San Onofre Nuclear Generating Station

Location:

San Clemente, California

Dates:

June 26 - 28, 2003 (Heavy loads demonstration)

August 4 - 8, 2003 (Pre-operational demonstration - Initial Inspection)

August 18 - 19, 2003 (Pre-operational demonstration - Final)

September 10 - 15, 2003 (First cask loading - Initial Inspection)

September 28 - October 1, 2003 (First cask loading - Final)

Inspectors:

J. V. Everett, Team Leader, Region IV

R. R. Temps, Safety Inspector, NRC Spent Fuel Project Office

J. F. Melfi, Resident Inspector, Palo Verde Nuclear Station

R. J. Evans, P.E., C.H.P, Senior Health Physicist, Region IV

J. D. Parrott, Senior On-Site Representative, NRC Las Vegas Office

M. A. Sitek, Resident Inspector, San Onofre Nuclear Station

W. C. Sifre, Reactor Inspector, Region IV

A. B. Barto, Nuclear Engineer, NRC Spent Fuel Project Office

R. V. Azua, Project Engineer, Region IV

T. W. Dexter, Security Consultant

E. M. Garcia, Health Physicist, Region IV

Approved By: D. Blair Spitzberg, Ph.D., Chief Fuel Cycle/Decommissioning Branch

Attachment 1: Supplemental Information

Attachment 2: Inspector Notes

ADAMS Entry: IR05000206-03-010; 05000361-03-010; 05000362-03-010; 072000041-03-

01 on 08/4/2003 - 10/01/2003; Southern California Edison Co., San Onofre

Nuclear Generating Station; Units 1, 2, 3. ISFSI Report. No violations.

-2-

EXECUTIVE SUMMARY

San Onofre Nuclear Generating Station

NRC Inspection Report 50-206/03-10; 50-361/03-10; 50-362/03-10; 72-41/03-01

On October 3, 2003, Southern California Edison loaded the first canister of San Onofre Nuclear

Generating Station (SONGS) Unit 1 spent fuel into their Independent Spent Fuel Storage

Installation (ISFSI). The ISFSI was located at the SONGS site adjacent to the Unit 1 reactor

facility. The Advanced NUHOMS Horizontal Modular Storage System was selected by Southern

California Edison to store the SONGS spent fuel under a general license. This cask system had

been approved for storage of irradiated nuclear fuel by the Nuclear Regulatory Commission (NRC)

under Certificate of Compliance No. 72-1029. Transnuclear, Inc., was the cask vendor for this

system.

Southern California Edison planned to move all Unit 1 spent fuel to the ISFSI by the spring

of 2005. This will involve moving 207 spent fuel assemblies from the Unit 1 spent fuel pool,

70 assemblies from the Unit 2 pool and 118 assemblies from the Unit 3 pool. Seventeen canisters

will be needed to hold the 395 Unit 1 spent fuel assemblies. The first five canisters to be loaded

into the ISFSI would remove all the Unit 1 spent fuel from the Unit 3 pool. The ISFSI pad currently

constructed at SONGS can accommodate 31 canisters. Each canister can hold 24 spent fuel

assemblies. The ISFSI pad will be expanded as additional space is needed and as dismantlement

activities at Unit 1 provide more space for ISFSI construction.

The inspections conducted by the NRC of Southern California Edisons dry cask storage project

provided a comprehensive evaluation of the licensees compliance with the requirements in the

NUHOMS Certificate of Compliance No. 72-1029, Technical Specifications, Final Safety Analysis

Report, NRCs Safety Evaluation Report and 10 CFR Part 72. The inspection consisted of a team

of eleven NRC inspectors performing inspections of various phases of activities over a period from

June 26 through October 1, 2003. Sixteen technical areas were reviewed during the inspections

including such topical areas as fuel verification, security, radiological programs, quality assurance,

training, and heavy loads. During the inspections, the licensee conducted numerous

demonstrations for NRC observance related to the operations of equipment and the

implementation of procedures to verify that all required aspects of the use of the NUHOMS cask

system at the SONGS site had been adequately incorporated into site programs and procedures.

The licensee had integrated together many of the programs for the Part 50 reactor operations and

the Part 72 ISFSI operations to allow for an efficient use of site resources.

During the various pre-operational demonstrations and during the loading of the first canister, the

SONGS workers demonstrated a comprehensive knowledge of the technical requirements related

to the loading and operations of an ISFSI and for compliance with 10 CFR Part 72. Much of this

advanced knowledge of ISFSI operations was a result of experience gained by Southern

California Edison personnel who provided manpower support to the Rancho Seco

decommissioned reactor for their ISFSI project. Rancho Seco completed the loading of

21 canisters on August 2002. Southern California Edison personnel were a key part of that

successful program. The knowledge and experience gained by the Southern California Edison

personnel while at Rancho Seco was brought back and integrated into the SONGS program. This

-3-

was obvious during discussions and interviews of the SONGS personnel which demonstrated

actual experience and knowledge of the issues that must be addressed in order to successfully

load spent fuel into the ISFSI.

During the loading of the first SONGS canister, the NRC provided 24-hour coverage of loading

operations for all critical tasks at the Unit 3 fuel handling building. This included fuel movement,

heavy lifts of the loaded canister, initial radiation surveys of the loaded cask, welding of the lids,

vacuum drying and helium backfill of the canister. Workers were knowledgeable of their assigned

tasks and had been well trained. Problems and issues were quickly identified and effectively

resolved. Shift supervision provided good oversight of work activities and workers always knew

who was in charge. Procedures were closely followed and a good questioning attitude was

demonstrated by all employees. There was good communications between the workers. Overall,

the licensees staff was well trained and highly motivated to perform work safely and in compliance

with the procedural requirements. The management team responsible for the ISFSI project had

worked hard to develop and implement a comprehensive program that would provide for the safe

operations of moving spent fuel at the SONGS site.

Details related to the 16 technical areas reviewed during this inspection are provided as

Attachment 2 to this inspection report. The following provides a summary of the findings of this

inspection.

Vacuum Drying, Helium Backfill and Helium Testing

!

Vacuum drying time limits established in Technical Specification 3.1.1 had been

incorporated into the licensees procedures. Canisters with a heat load greater than

12 kW were required to be vacuum dried within a specific time frame. The licensees

procedure included provisions for establishing a helium environment in the canister or re-

flooding the canister, as required by the technical specification, if the time limit was not

met.

!

The licensee had implemented a stepped vacuum drying process consistent with the

requirements in Technical Specification 3.1.1. This stepped process of lowering the

pressure in the canister to certain predetermined levels and holding at that level for a

period of time was intended to reduce the likelihood of ice blockage in the system lines.

The final vacuum drying pressure requirement for the canister was 3 torr. The licensees

procedures specified a value of 2.8 torr to account for instrument error and to provide an

extra margin for compliance.

!

Helium backfill pressure requirements established in Technical Specification 3.1.2 had

been incorporated into the licensees procedures. Provisions for documenting the final

helium backfill pressure reading was provided in the procedure, including independent

verification and sign-off by quality control personnel.

!

Helium leak rate testing of the inner lid weld and the vent/siphon port cover welds required

by Technical Specification 3.1.3 had been incorporated into the licensees procedures.

Procedural requirements included specifications for the helium to be $99 percent pure and

-4-

the leak rate to be #10-7 standard cubic centimeters/second. Procedures also required

helium leak test personnel to be qualified to the standards in SNT-TC-1 Personnel

Qualification and Certification of Nondestructive Testing.

Emergency Planning

!

Emergency planning provisions for the ISFSI had been incorporated into the site-wide

emergency plan. This included specific emergency action levels for fires, loss of canister

integrity and security events.

!

The ISFSI design provided for accessability by emergency personnel and vehicles. The

licensee maintained their own site fire and medical response capability. Offsite fire,

security and medical support organizations were available to augment the site emergency

organization.

Fire Protection

!

The ISFSI had been incorporated into the San Onofre Updated Fire Hazards Analysis.

Administrative controls were established to limit the quantity of combustible and flammable

liquids around the ISFSI and near the transport path during movement of the canister.

!

Analysis had been completed to evaluate the effect on the ISFSI of site specific explosive

hazards and to confirm that the design of the ISFSI was adequate for the postulated

external pressure levels that could result from an explosion.

Fuel Verification

!

The SONGS Unit 1 spent fuel was stored in four locations: 270 assemblies at the General

Electric spent fuel storage pool located in Morris, Illinois; 207 assemblies in the SONGS

Unit 1 spent fuel pool; 70 assemblies in the SONGS Unit 2 spent fuel pool; and 118

assemblies in the SONGS Unit 3 spent fuel pool. The first loading campaign will load the

Unit 1 spent fuel stored in the Unit 3 spent fuel pool. This will require five canisters.

!

The requirements in Certificate of Compliance No. 1029 for the type of fuel that can be

stored in the Advanced NUHOMS 24PT1 canisters was evaluated against the SONGS

Unit 1 spent fuel planned for loading in the first five canisters. Criteria included type of

fuel, cladding, decay heat, burn-up, neutron/gamma source strength, cooling time and

enrichment. All spent fuel assemblies met the technical specification requirements.

!

Twenty-seven Unit 1 fuel assemblies had been identified as damaged. Of these, four

were in the Unit 3 spent fuel pool and will be included in the first loading campaign of five

canisters. Damaged fuel assembles were required to be placed in special failed fuel cans

inside the canisters. Criteria used by the licensee for identifying which fuel assemblies

were damaged was consistent with NRC guidance.

-5-

!

The licensee had established provisions for independent verification of the correct loading

of the canister. This included videotaping the location of the spent fuel after loading in the

canister.

!

Because the NUHOMS canisters were inserted into the concrete storage modules

horizontally, special center of gravity considerations for the canisters were necessary to

prevent rotation of the canister during insertion into the concrete storage module.

Technical specifications required the center of gravity of the loaded canister to be within

0.1" of the canisters radial center of gravity. Licensee calculations for the first five

canisters demonstrated compliance with this limit. The largest deviation from the radial

center of gravity was 0.0042".

Compliance with 10 CFR Part 72 General License Requirements

!

The licensee evaluated the bounding environmental conditions specified in the NUHOMS

Final Safety Analysis Report and Certificate of Compliance No. 1029 technical

specifications against the conditions at the SONGS site. This included: tornados/high

winds, flood, seismic events, snow/ice loading, tsunami, lightning, burial under debris,

normal and abnormal temperatures, and fires/explosions. The site environmental

conditions at the SONGS ISFSI were bounded by the NUHOMS cask design parameters.

!

Radiation levels at the ISFSI were calculated for workers during loading operations and

routine surveillance activities. Doses were calculated for the controlled area boundary.

Doses at the controlled area boundary were projected to be 1 mrem/year, well below the

10 CFR 72.104 limit of 25 mrem/year. Projected worker doses to conduct the daily visual

inspection were 172 millirem/year. Weekly radiation surveys of the ISFSI could add

49 millirem/year. A conservative estimate for loading a cask was determined to be

3117 millirem per canister loading.

!

The licensee performed an evaluation of the site programs that could be impacted by the

addition of an ISFSI. The evaluation included the radiation protection program, emergency

planning program, quality assurance program, training program and the reactor technical

specifications and Part 50 license. Revisions to the programs to incorporate the ISFSI

were identified and implemented.

!

The NUHOMS Certificate of Compliance and Final Safety Analysis Report had been

reviewed by the licensee to verify that the design basis for the NUHOMS cask system and

the conditions and requirements in the Certificate of Compliance and Final Safety Analysis

Report were met.

Heavy Loads

!

The licensee had incorporated the special requirements related to the ISFSI project into

the site heavy loads programs and procedures. Crane operators interviewed during the

ISFSI inspections were knowledgeable of the special handling requirements related to the

heavy spent fuel casks.

-6-

!

Special lifting device height limits and temperature restrictions during movement of the

casks had been incorporated into the licensees procedures consistent with the

requirements in the Certificate of Compliance. This included the requirement to perform

an inspection of the cask for damage after any drop of 15" or higher.

!

The maximum weight of the loaded transfer cask had been determined by the licensee to

verify the adequacy of the lift capability of the cranes planned for use in moving the spent

fuel. A loaded cask being removed from the spent fuel pool represented the maximum

weight to be lifted and exceeded the lifting capacity of the current Unit 1 crane. The

licensee had purchased new single failure proof cranes for installation and use during the

cask loading operations. The Unit 3 crane was rated at 125 tons. The Unit 1 crane would

be up-rated from 100 tons to 105 tons to account for the estimated 104.1 ton weight of the

loaded cask.

!

A safe loads path had been identified and analyzed for moving the spent fuel from the

spent fuel pool to the ISFSI. Provisions were established in procedures and through the

use of limit switches to prevent the crane from moving the loaded cask outside the

boundaries of the safe load path while in the fuel building. Calculations were performed

for the roadway between the plant and the ISFSI to verify that the path was structurally

capable of handling the weight of the loaded transfer cask and trailer.

!

The licensees heavy loads procedural requirements related to the transfer cask trunnions

and the slings used for lifting the canister lid were verified against industry standards and

manufacturer requirements for load tests, safety margins and inspection/maintenance.

!

The adequacy of the transport trailer for the expected weight of a loaded canister and the

ability of the transport trailer to safely secure and move the cask to the ISFSI was verified.

Pad/Storage Modules

!

Requirements in the Final Safety Analysis Report related to the placement of the storage

modules on the ISFSI pad and the module-to-module connections required for the high

seismic conditions at the SONGS site were being implemented.

!

The concrete storage module thermal monitoring program had been incorporated into

procedures. This included the daily monitoring of the storage module temperature and the

daily verification that the air inlets and outlets were free from debris.

!

The thickness requirements for the concrete storage module roof and shield walls to

ensure radiological levels would be below regulatory limits were verified by direct

observation of the storage modules under construction and a review of the design

drawings.

!

The seismic design of the ISFSI pad to meet the potential earthquake intensity at the

SONGS site and to address liquefaction of the soil under the pad was inspected by the

-7-

NRC on April 9, 2002, and documented in Inspection Report 50-206/02-07;72-41/02-01

issued May 21, 2002 (NRC Adams Document ML021410532).

Pre-Operational Testing

!

The licensee successfully completed all the required pre-operational test requirements

specified by the Certificate of Compliance. This include the loading, welding, drying, and

backfilling of a canister and the unloading of a sealed canister. A weighted canister was

used to demonstrate heavy load activities, transport between the Unit 3 facility and the

ISFSI and insertion/removal of a canister into the concrete storage module.

Procedures and Technical Specification Requirements

!

The licensee had developed the required operating procedures and programs required by

the Certificate of Compliance.

!

The adequacy of the level of detail in the procedures was verified by reviewing

requirements in the Final Safety Analysis Report related to handling the cask at the spent

fuel pool. All requirements reviewed had been incorporated as operational steps in the

licensees procedures.

Quality Assurance

!

The licensee had implemented their approved reactor facility Part 50 quality assurance

program for the activities associated with the ISFSI. Effective implementation of the

program was observed for all phases of ISFSI activities including procurement, control of

measuring equipment, corrective actions, design control, receipt inspections, storage and

audits.

!

Southern California Edison was constructing their canisters onsite as a fabricator to

Transnuclear, Inc. An inspection conducted by the NRCs Spent Fuel Project Office on

March 3-6, 2003, and documented in Inspection Report 72-1029/2003201 issued March 6,

2003, found all work activities were being properly controlled under the Southern

California Edison quality assurance program (NRC Adams Document ML030940163).

!

The licensees quality assurance organization had implemented a comprehensive quality

assurance audit and inspection program that was responsive to applying additional

oversight to selected work activities where problems were being identified. This was most

evident in the decision to place onsite quality assurance inspectors at one of the vendors

to ensure the quality of the concrete storage modules.

Radiation Protection

!

Requirements for radiological and contamination surveys described in the Final Safety

Analysis Report had been incorporated into the licensees health physics program for the

-8-

loading of the casks. This included special precautions related to potential high dose rate

work activities.

!

Calculations performed by the licensee to evaluate the potential radiological doses during

normal operations at the ISFSI and during an accident demonstrated compliance with the

limits specified in 10 CFR 72.104 and 10 CFR 72.106.

!

The licensee had identified the reactor Part 50 exclusion area as the controlled area for

the ISFSI. The distance from the ISFSI to the exclusion area boundary met the required

minimum distance for a controlled area around an ISFSI specified in 10 CFR 72.106.

Southern California Edison was authorized, through a signed easement, to remove

personnel from the exclusion area in the event of an emergency.

!

The licensee had determined a dose conversion factor for neutron doses to workers to

account for the neutron spectrum expected with the loaded canisters.

!

Environmental monitoring for the ISFSI had been incorporated into the existing reactor

environmental monitoring program. Additional thermoluminescent dosimeters had been

placed around the ISFSI to monitor the increase in radiation levels expected due to the

storage of the spent fuel. Dosimeters had been placed in service in 2001 and had been

used to collect background data that could be compared with the ongoing monitoring after

spent fuel was placed in the ISFSI to determine the level of increase in radiation levels.

Records

!

A records system had been established by the licensee under their reactor Part 50 quality

assurance program. Records required for retention by 10 CFR 72.174, 10 CFR 72.212,

10 CFR 72.234 and the Final Safety Analysis Report had been identified in the licensees

program as required records for retention.

!

An optical disk system was being used for permanent storage of the records. The quality

assurance plan required that ISFSI related records be retained for the duration of the

license or certificate of compliance.

!

The required 90-day notification prior to loading the first cask had been made to the NRC

on May 5, 2003. The requirement to provide notice to the NRC within 30 days of use of a

cask had been incorporated into the appropriate procedure.

Safety Reviews

!

Changes to the site related to the construction and operation of the ISFSI were being

evaluated in accordance with 10 CFR 72.48 and 10 CFR 50.59 requirements. No issues

were identified during the review of selected safety screenings.

-9-

Security

!

Security for the ISFSI had been integrated into the overall site security program. The

security plan and procedures had been revised to incorporate specific provisions for

responding to a security threat at the ISFSI. Arrangements had been established to obtain

support from local law enforcement agencies during a security event.

!

Security force personnel were trained on security requirements for the ISFSI including the

implementation of access controls, key controls and compensatory actions.

!

Physical security systems had been installed and were operational. This included the

protected area fence, lighting systems, intrusion detection systems and backup power.

!

Arrangements had been made for a moving protected area around the cask during

transport from Unit 3 to the ISFSI.

Training

!

The licensee had implemented a training program for workers assigned to the ISFSI that

incorporated the topics listed in the technical specifications and provided for

documentation of completion of training and job task qualification.

!

Specific training needs had been identified and incorporated into training for operations,

maintenance and health physics personnel as required by the Final Safety Analysis

Report.

!

A computerized training records system had been established by the licensee to track

completion of training by individuals.

Welding/Nondestructive Testing

!

Requirements for hydrogen monitoring during welding of the inner cask lid had been

incorporated into the procedures. The alarm set point had been established at 50 percent

of a lower explosive limit for hydrogen. During welding of the inner lid welds, hydrogen

levels were measured from 3 percent to 8.4 percent of the lower explosive limit.

!

The licensee was performing the required dye penetrant examinations of welds on the

canister in accordance with the Final Safety Analysis Report. Dye penetrant examination

procedures had been developed for both normal temperatures and for the higher

temperatures that could be encountered with the hotter casks.

!

Nondestructive examination requirements for welds were adequately specified in

procedures and on drawings.

!

Nondestructive examination personnel were qualified to the requirements in SNT-TC-1A

for performing weld examinations of the type required on the canisters.

-10-

Exit Meetings

The inspectors presented the inspection results to members of licensee management at the

conclusion of the various key stages of the inspection on August 8, August 19 and October 1,

2003. The licensee acknowledged the findings presented. The licensee did not identify as

proprietary any information provided to, or reviewed by, the inspectors that had been incorporated

into the inspection effort.

ATTACHMENT 1

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

J. Agosti, Lead Auditor, Procurement Quality

A. Alexander, Security Lock and Key Specialist

J. Appel, Engineer, Design Engineering

R. Ashe-Everest, Project Manager, Spent Fuel Cask Transfer Operations

V. Barone, Cognizant Engineer, Dry Cask Storage

R. Beatty, Supervisor, Unit 1 Security

M. Bise, Program Analyst

J. Bock, Project Manager, Project Management and Engineering Support

R. Bordon, Surveillance Team Supervisor, Nuclear Oversight and Assessment

G. Broussard, Manager, Security Operations and Equipment Performance

R. Brown, ISFSI Support

R. Busnardo, Project Manager for Canister Fabrication, Nuclear Generation Maintenance

G. Cook, Supervisor, Regulatory Compliance

T. Cook, Shift Commander, Security

P. Coughlin, QA/QC Vendor Oversight, Nuclear Oversight and Assessment

J. Custer, Manager, ISFSI Operations

D. Czapski, Quality Control Inspector, Nuclear Oversight and Assessment

S. Davis, Nuclear Security Officer, Security

D. Faasamala, Security Lock and Key Specialist

G. Ferrigno, Health Physics Planner

B. Gossett, Engineer, Nuclear Fuel Services

R. Granaas, Engineer, Nuclear Fuel Services

K. Gribble, Maintenance Supervisor

P. Gyswyt, Design Engineering

N. Hansen, Radiological Environmental Monitoring Program Specialist

S. Hunn, Administrative Manager

N. Jervis, Supervisor, Security Operations

W. Kotteakos, Supervisor, Quality Control/Nondestructive Examinations

J. Larson, Supervisor, Procurement Quality

J. Linville, Acting Shift Commander, Security

M. Mason, Supervisor, Fabrication

M. McBrearty, Engineer, Nuclear Regulatory Affairs

A. Meichler, Supervisor, Weld Engineering

D. Miller, Fuel Team Leader, Training

G. Moore, Manager, Decommissioning Oversight

J. Morales, Manager, Dry Cask Storage

M. Mullen, Nuclear Security Officer, Security

S. Ordorica, Nondestructive Examination Inspector

A. Ockert, Fire Protection Engineer

M. Orewyler, Maintenance Supervisor

R. Osborne, Manager, 72.48 Program

D. Pilmer, Manager, Dry Cask Fuel Storage Licensing

-2-

D. Ripley, Manager, Maintenance Training

M. Russell, Technical Specialist

S. Salwach, Nuclear Engineer, Maintenance Engineering

D. Schell, Supervisor, Fabrication Welding

J. Scott, Emergency Planning Engineer

M. Speer, Maintenance Supervisor

D. Stoeckel, Technical Specialist, Maintenance Engineering

T. Swindle, Shift Commander, Security

R. Todd, Supervisor, Security Equipment Performance

J. Valsvig, Welding Technician

M. Watson, Shift Commander, Security

S. Wong, Nondestructive Examination Inspector

H. Wood, Surveillance Team Member, Nuclear Oversight and Assessment

T. Yee, Consulting Engineer, Design Engineering

G. Zwissler, Manager, Administration

Leak Test Specialists

D. Hecksel, Leak Testing Specialist

Transnuclear, Inc.

U. Farradj, Project Manager

INSPECTION PROCEDURES USED

60854

Pre-operational Testing of an ISFSI

60855

Operations of an ISFSI

60856

Review of 10 CFR 72.212(b) Evaluations

60857

Review of 10 CFR 72.48 Evaluations

81001

ISFSI Security

ITEMS OPENED AND CLOSED

Opened

None

Closed

None

Discussed

None

-3-

LIST OF ACRONYMS USED

ALARA

as low as reasonably achievable

ANSI

American National Standards Institute, Inc

CFR

code of federal regulations

DAC

derived air concentration

DSC

dry shielded canister

FSAR

final safety analysis report

GWd/MTU

gigawatt days/metric ton uranium

ISFSI

independent spent fuel storage installation

kW

kilowatt

MOX

mixed-oxide fuel

NDE

nondestructive examinations

NRC

Nuclear Regulatory Commission

psi

pounds/in2

psig

pounds/in2 (gauge)

QA

quality assurance

SAR

safety analysis report (same as final safety analysis report)

SNT-TC

Society of Nondestructive Testing-Technical Council

SONGS

San Onofre Generating Station

std-cc/sec

standard cubic centimeters/second

Tech Specs

technical specifications

UFSAR

updated final safety analysis report