IR 05000312/2005004

IR 05000312-05-004, Sacramento Municipal Utility District, Energy Supply, 10/31/ Through 11/03/2005 Inspection Conducted at Licensee'S Rancho Seco Nuclear Generating Station

ML053220561
Person / Time
Site:	Rancho Seco
Issue date:	11/18/2005
From:	Spitzberg D Division of Nuclear Materials Safety IV
To:	Shetler J Sacramento Municipal Utility District (SMUD)
References
IR-05-004
Download: ML053220561 (17)

Text

ber 18, 2005

SUBJECT:

NRC INSPECTION REPORT 050-00312/05-004

Dear Mr. Shetler:

An NRC inspection was conducted on October 31 through November 3, 2005, at your Rancho Seco Nuclear Generating Station. At the conclusion of the site visit, a briefing was conducted with the acting Plant Manager and other members of your staff. The inspector reviewed and evaluated additional licensee documents submitted after the visit. These reviews and the inspection were completed on November 16, 2005. The enclosed report presents the scope and results of the inspection.

The inspection was an examination of activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection included reviews of the maintenance and surveillance programs; status of the reactor vessel internals segmentation; other decommissioning activities; and solid radioactive waste management and transportation of radioactive materials.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's 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 Mr. Emilio Garcia, Health Physicist, at (530) 756-3910 or the undersigned at (817) 860-8191.

Sincerely,

/RA/

D. Blair Spitzberg, Ph.D., Chief Fuel Cycle and Decommissioning Branch Docket No.: 050-00312 License No.: DPR-54

Sacramento Municipal Utility District -2-

Enclosure:

NRC Inspection Report 050-00312/05-004

REGION IV==

Docket Nos.: 050-00312 License Nos.: DPR-54 Report Nos.: 050-00312/05-004 Licensee: Sacramento Municipal Utility District Facility: Rancho Seco Nuclear Generating Station Location: 14440 Twin Cities Road Herald, California Dates: October 31 through November 3, 2005 Inspector: Emilio M. Garcia, Health Physicist Approved By: D. Blair Spitzberg, Ph.D., Chief Fuel Cycle and Decommissioning Branch Attachments: Supplemental Information Partial List of Documents Reviewed

-2-EXECUTIVE SUMMARY Rancho Seco Nuclear Generating Station NRC Inspection Reports 050-00312/05-004 The licensee was actively conducting dismantling activities in the reactor building, auxiliary building, spent fuel building and exterior areas. All spent fuel had been removed from the spent fuel pool and placed in the Independent Spent Fuel Storage Installation (ISFSI). The reactor vessel head, pressurizer, pressurizer drain tank and the two steam generators had been removed from the reactor building and shipped to an offsite disposal facility. Segmentation of reactor vessel internals was underway.

Maintenance and Surveillances

• The licensee no longer had any safety-related structures, systems or components. The licensee continued to maintain their liquid effluent monitor. Checks and calibrations of the liquid effluent monitor and related components had been conducted at the required intervals (Section 1).

Decommissioning Performance and Status Review

• Dismantlement activities continued. Problems with methods planned for the segmentation of the reactor vessel internals resulted in changes in techniques, work locations and schedule. The licensee expected to complete the reactor vessels internal segmentation project in early March 2006. A vender had been selected to provide water jet equipment and training for the reactor vessel segmentation. The radiological characterization surveys of the reactor building dome were scheduled to begin in January 2006 (Section 2).

Solid Radioactive Waste Management and Transportation of Radioactive Materials

• Surveillance activities related to solid radwaste management and to transportation of radioactive materials were being effectively implemented (Section 3.1).

• Changes to the licensees organization, personnel, equipment, and procedures had not negatively effected the solid radwaste management and transportation of radioactive materials program (Section 3.2).

• Individuals responsible for processing, testing, storage, and shipping (including certification) of low level radioactive waste and other radioactive materials had received the required training and retraining (Section 3.3).

• The licensee maintained copies of the applicable regulations and the licenses of recipients of radioactive materials, and had identified those individuals authorized to certify low level radioactive waste shipments (Section 3.4).

-3-Report Details Summary of Facility Status The Rancho Seco Nuclear Generating Station was permanently shut down in June 1989. All spent reactor fuel has been moved to an onsite Independent Spent Fuel Storage Installation (ISFSI). At the time of this inspection, the licensee was conducting decommissioning activities at the site. Decommissioning was being performed under the provisions of the incremental decommissioning option of Rancho Secos Post Shutdown Decommissioning Activities Report, dated March 20, 1997.

Decommissioning work activities included the auxiliary building, reactor building, spent fuel building and exterior areas. All major components in the auxiliary building had been removed, packaged and shipped for disposal. In the reactor building, the major piping, the four reactor coolant pumps, the core flood tanks, reactor vessel head, pressurizer, pressurizer drain tank, and the two steam generators had been removed, packaged and shipped offsite for disposal.

In the fuel handling building, the spent fuel pool water had been processed and released. Most of the pool liner plates had been cut, removed and shipped for disposal. During this inspection, the reactor vessel internals segmentation project was continuing.

1 Maintenance and Surveillances (IP 62801)

a. Inspection Scope The inspector reviewed the status of required surveillances and testing. The inspector discussed this area with the Maintenance Superintendent and reviewed selected records.

b. Observations and Findings The current listing of the status of surveillances and routine tests was reviewed. As of November 3, 2005, there were no overdue surveillance or routine tests.

With the relocation of the spent fuel to the ISFSI, the licensee no longer had any safety-related structures, systems or components (SSC) as defined in 10 CFR 50.65(b)(1), nor any non-safety-related SSC as defined in 10 CFR 50.65(b)(2). The licensee had reviewed their Maintenance Rule procedure and concluded that it was no longer required with fuel in the ISFSI. With the processing of the water in the spent fuel pool, the potential for significant liquid effluent releases was greatly diminished; however, the licensee had opted to maintain their liquid effluent radiation monitor.

The inspector reviewed the maintenance of liquid effluent radiation monitor, R-15017A.

The licensee performed quarterly tests and annual calibrations of this monitor. Records maintained by the licensee indicated that the licensee had performed these

-4-surveillances at the required intervals. The inspector also reviewed selected records of surveillances related to the waste water flow rate indicator and totalizer, retention basin discharge flow loop, effluent sampling, and holdup tank limits. Records maintained by the licensee indicated that the licensee had performed these surveillances at the required intervals.

c. Conclusion The licensee no longer had any safety-related structures, systems or components. The licensee continued to maintain their liquid effluent monitor. Checks and calibrations of the liquid effluent monitor and related components had been conducted at the required intervals.

2 Decommissioning Performance and Status Review (IP 71801)

a. Inspection Scope The inspector interviewed cognizant personnel and reviewed selected documents related to changes in the reactor vessel internals dismantlement, the projected schedule for the reactor vessel segmentation, and the reactor building dome characterization.

The inspector also toured the site to observe work activities underway which included observation of housekeeping, safety practices, fire loading and radiological controls.

b. Observations and Findings The Dismantlement Superintendent - Operations briefed the inspector on changes to the reactor vessel internals (RVI) segmentation project schedule. The contractors performing the RVI segmentation had encountered a number of problems with the tools originally designed to segment the RVI which necessitated changes in tools and on the schedule for completion. The schedule as of November 1, 2005, called for completion of the project by the beginning of March 2006.

The Dismantlement Superintendent - Operations also briefed the inspector on the licensees plans for the segmentation and dismantlement of the reactor vessel. The licensee had contracted for equipment and training to use a remotely controlled manipulator to operate a small water jet cutting tool. The equipment would be operated by licensee staff and be performed in a dry reactor vessel. The schedule as of November 1, 2006, called for the deployment of the manipulator and water jet shortly after completion of the RVI segmentation project. The reactor dismantlement was projected to be completed by the end of calender year 2006. In addition, the licensee intends to build a platform on top of the main reactor building crane to permit access to the dome of the containment. A person lift will be placed on the platform to allow for radiological characterization surveys of the containment dome. The licensee projected completing the design by mid November 2005, with installation by the third week in December 2005. Radiological characterization surveys would begin in January 2006.

The licensee was continuing the process of segmenting the reactor vessel internals to separate and package the irradiated components into the various waste categories. A

-5-tour of the reactor building and other areas of the plant was conducted to observe dismantling and decommissioning activities in progress. The work observed was being conducted in a safe and orderly manner. Radiological controls, including postings and barriers, were in place. Good housekeeping and fire protection practices were noted in areas observed.

During the site visit the licensee experienced a minor problem. During dismantlement activities in the area of the former regenerant hold-up tanks, the discharge line from the polishing demineralizers sump to the retention basins was damaged. A hydraulic breaker was being used to remove concrete around the line when the hammer tip inadvertently broke the line. The inspector observed the damage shortly after it happened. No water was present in the line at the time and radiological surveys did not identify any contamination. No individual was injured nor radiologically contaminated.

The licensee opened a potential deviation from quality (PDQ) report to address the problem and an interim disposition was developed.

c. Conclusion Dismantlement activities continued. Problems with methods planned for the segmentation of the reactor vessel internals resulted in changes in techniques, work locations and schedule. The licensee expected to complete the reactor vessels internal segmentation project in early March 2006. A vender had been selected to provide water jet equipment and training for the reactor vessel segmentation. The radiological characterization surveys of the reactor building dome were scheduled to begin in January 2006.

3 Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)

3.1 Audits and Surveillances a. Inspection Scope The inspector reviewed the licensees audit and surveillance program and selected several surveillances of the solid radioactive waste management and transportation of radioactive materials program for detailed review.

b. Observations and Findings This area was last inspected January 31 through February 3, 2005 (see inspection report 50-312/05-01). No audits of this area had been performed since the last inspection. The inspector reviewed the licensees surveillance log and noted that in calender year 2005, of the 21 surveillances that had been conducted, 8 related to radioactive waste shipments and an additional 2 addressed waste stream evaluation.

The inspector selected four surveillances for review: Surveillance Reports 05-S-004, approved on February 7, 2005; 05-S-008, approved on May 11, 2005; 05-S-011, approved on June 1, 2005; and 05-S-018, approved on September 22, 2005.

-6-The individual assigned to perform the surveillances was trained and qualified and was independent of the areas being audited. The surveillances included performance based elements. No quality related problems were identified during the surveillances related to solid radwaste management and transportation of radioactive materials.

Recommendations identified in the surveillances were addressed by the audited department.

c. Conclusion Surveillance activities related to solid radwaste management and to transportation of radioactive materials were being effectively implemented by the licensee.

3.2 Changes a. Inspection Scope The inspector interviewed cognizant personnel and reviewed selected documents to determine if any major changes had taken place since the last inspection in the organization, personnel, facilities, equipment, programs or procedures that may have effected the solid radwaste management and transportation of radioactive materials program.

b. Observations and Findings The reporting organization for the radioactive waste and transportation group had changed. The former Radwaste Operations Superintendent had been assigned new responsibilities. Now the Radwaste Supervisor and Radwaste Technical Analyst reported to the Dismantlement Superintendent - Radiological. Also, the position of contract Radiological Engineer had been eliminated. The licensee had procured a significant new piece of equipment, the remotely operated grappler, which was used for loading and unloading liners in the interim onsite storage building. Operation of this grappler was controlled by procedure RP.309.IV.01, IOS Building Operations, which had been revised effective April 27, 2005. Three other procedures in the Radwaste Control Manual had also been revised and are listed in Attachment 2.

c. Conclusions Changes to the licensees organization, personnel, equipment, and procedures had not negatively effected the solid radwaste management and transportation of radioactive materials program.

-7-3.3 Training and Qualifications of Personnel a. Inspection Scope The inspector interviewed cognizant personnel and reviewed selected documents to determine if individuals that were responsible for processing, testing, storage, and shipping (including certification) of low level radioactive waste and other radioactive materials had received training and periodic retraining in the Department of Transportation (DOT) and NRC regulatory requirements, the waste burial license requirements, and in the instructions and operating procedures.

b. Observations and Findings The Dismantlement Superintendent - Radiological stated that the system for tracking the training of individuals involved in the processing, testing, storage, and shipping (including certification) of low level radioactive waste and other radioactive materials had been previously maintained as a tickler file controlled by the former Radwaste Operations Superintendent. The licensee intended to formalize the tracking process using their current commitment tracking system. The licensee would annually review the training requirements for the group and then schedule the necessary training for the calendar year.

The inspector selected six individuals who had been responsible for processing, testing, storage, and shipping (including certification) of low level radioactive waste and transportation of other radioactive materials since this area was last inspected. Records maintained by the licensee indicated that all had received the initial training required by 49 CFR 172.704(a) and they were not overdue for refresher training as required by 49 CFR 172.704(c).

c. Conclusions Individuals responsible for processing, testing, storage, and shipping (including certification) of low level radioactive waste and other radioactive materials had received the required training and retraining.

3.4 Implementation of the Solid Radioactive Waste Program a. Inspection Scope The inspector interviewed cognizant personnel and reviewed selected documents to determine if the licensee maintained copies of the applicable regulations and licenses of recipients of radioactive materials shipped from the site, and had identified those individuals authorized to certify low level radioactive waste shipments in accordance with Section II of Appendix F to 10 CFR 20.1001-20.2402.

-8-b. Observations and Findings The licensee maintained paper copies and had access to electronic copies of the NRC, DOT and States of Utah and Tennessee regulations, and had copies of the licenses for the low level radioactive waste disposal site and the materials recovery site to which licensed material were shipped. The licensee issued an annual memorandum to file that identified the individuals, their signatures and their initials that were authorized to certify radioactive shipments. This memorandum also included the names, signature and initials of the individuals authorized to perform quality assurance functions associated with radioactive shipments generated at the site. The inspector reviewed this memorandum dated March 10, 2005.

c. Conclusions The licensee maintained copies of the applicable regulations and the licenses of recipients of radioactive materials, and had identified those individuals authorized to certify low level radioactive waste shipments.

3.5 Shipping of low level radioactive waste for Disposal, and Transportation of other Radioactive Material a. Inspection Scope The inspector observed portions of the removal of a Class C waste container from the reactor building. The inspector reviewed records of radioactive materials shipments.

b. Observations and Findings On November 2, 2005, the licensee loaded and removed cask LXU-805-0359 from the reactor building. This cask contained shipping package RS-RVI-019 which was classified as Class C waste. The inspector noted that the licensee had taken appropriate precautions to maintain radiological exposure ALARA.

As of November 3, 2005, 30 shipments of radioactive material had been completed in 2005. Three records were selected for reviewed. These were for Shipments05-006, 05-020, and 05-028. The emergency response telephone number listed on the waste manifests was confirmed as the telephone number for the Rancho Seco secondary alarm station. The shipping records included copies of the radiological surveys conducted, Form 540 Uniform Low-Level Radioactive Waste Manifest as applicable, emergency response information, instructions to the carrier for maintenance of exclusive use shipment controls and the vehicle inspection report. Documents requiring shipper certification were signed by a licensee representative. Records of the training of individuals who signed or otherwise performed functions related to the transport of hazardous material were reviewed. The individuals involved with these shipments had received appropriate training as required by 49 CFR 172, Subpart H.

The Dismantlement Superintendent - Radiological stated that the licensee had not received any notices of non-compliance from DOT or other competent state authorities.

-9-c. Conclusion The licensee had implemented a transportation program for radioactive materials and radioactive waste in accordance with NRC and U.S. Department of Transportation regulations.

4. Followup (IP 92701)

(Discussed) IFI 050-00312/0503-02: Licensees Independent Assessment of the Initial Investigation into the Unauthorized Entry into a Secured High Radiation Area: During a previous inspection, the NRC inspector identified that the licensee investigations into the unauthorized entry into a secured high radiation area had not disclosed pertinent details.

The licensee initiated an independent assessment of the initial investigation. The licensees independent assessment, Surveillance Report 05-S-020, had been completed and come to some conclusions including: 1) the initial investigations had not been conducted independently; 2) not everyone involved in the incident had been properly interviewed about the incident and these individuals did not know that it was their obligation to inform the investigators about what they knew; 3) two individuals actually entered the secured high radiation area; 4) the applicable procedure appears to be unclear; and 5) some workers had safety concerns they did not want to bring up through supervisors.

Surveillance Report 05-S-020 also include recommendations: 1) Separate individuals should conduct radiation protection occurrence reports and PDQ investigations; 2) provide retraining to individuals on their obligation to self report incidents; 3) contractors and radiation protection personnel should meet to discuss their working relationship and improvements to prevent reoccurrence; 4) review and rewrite the applicable procedure; and 5) establish a Nuclear Safety Concerns Group that allows workers the opportunity to confidentially discuss their safety and health physics concerns.

The commitment management review group (CMRG) reviewed the draft report of Surveillance Report 05-S020 and prepared their own report. The CMRG report identified a number of recommendations that were similar to those made by Surveillance Report 05-S020. In addition, the CMRG recommended that the contractors supervisors performance should be evaluated to determine if disciplinary action was appropriate and that a site wide survey should be conducted to assess the potential for a chilled work environment. At the end of the inspection the licensee had not determined how some of these recommendations would be implemented. This item remains open.

5 Exit Meeting Summary The inspector presented the inspection results to the acting plant manager and other members of licensee staff at the exit meeting on November 3, 2005. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.

ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED Sacramento Municipal Utility District M. Braun, Sr. Nuclear Engineer M. Bua, Radiation Protection/Chemistry Superintendent R. Coder, Radwaste Supervisor J. Field, Engineering Superintendent, Acting Plant Manager W. Hawley, Dismantlement Superintendent - Operations R. Jones, Sr. Nuclear Engineer S. Nicolls, Radiological Health Supervisor G. Roberts, Maintenance Superintendent E. Ronningen, Dismantlement Superintendent - Radiological Contractors T. Garcia, Site Supervisor, Bigge Power Constructors C. Martens, Sr. Radiation Protection Technician, Bartlett Services, Inc.

INSPECTION PROCEDURES USED IP 62801 Maintenance and Surveillances IP 71801 Decommissioning Performance and Status Review IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92701 Followup ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed 050-00312/0503-02 IFI Licensees Independent Assessment of the Initial Investigation into the Unauthorized Entry into a Secured High Radiation Area.

-2-LIST OF ACRONYMS ALARA As Low As Reasonably Achievable CFR Code of Federal Regulations CMRG Commitment Management Review Group DOT Department of Transportation IFI Inspection Follow-up Item IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation IOS Interim Onsite Storage Building PDQ Potential Deviation from Quality RP Radiation Protection RSAP Rancho Seco Administrative Procedure RVI Reactor Vessel Internals SSC Structures, Systems or Components

ATTACHMENT 2 PARTIAL LIST OF DOCUMENTS REVIEWED Audits and Surveillances

• Surveillance Report 05-S-004, Verify that the radioactive waste shipment meets DOT and SMUD requirements prior to departure from Rancho Seco, surveillance period January 6 and February 1-2, 2005, issued February 7, 2005.

• Surveillance Report 05-S-008, Verify that the disposition of Low Level Radioactive Waste (LLRW) at Envirocare of Utah is consistant with NUPIC Criteria, surveillance period April 11-14, 2005, issued May 11, 2005.

• Surveillance Report 05-S-011, Verify that the radioactive waste shipment meets DOT and SMUD requirements prior to departure from Rancho Seco, surveillance period May 26, 2005, issued June 1, 2005.

• Surveillance Report 05-S-018, Verify that the radioactive waste shipment meets DOT and SMUD requirements prior to departure from Rancho Seco, surveillance period September 21, 2005, issued September 22, 2005.

• Surveillance Report 05-S-020, Determine the events surrounding the unescorted entry of Leotice Wood into a Secured High Radiation Area on August 10, 2005, and determine recommendations to prevent reoccurrence of the unescorted entry, surveillance period October 3-11, 2005, issued on October 27, 2005.

• CMRG Review of Surveillance Report 05-S-020, undated.

Data Sheets

• Surveillance Procedure Manual, SP-418A, Quarterly Test of Liquid Effluent Radiation Monitor (R-15017A), Revision 21, effective April 19, 2004. Surveillance approved March 9, 2005.

• Surveillance Procedure Manual, SP-418A, Quarterly Test of Liquid Effluent Radiation Monitor (R-15017A), Revision 21, effective April 19, 2004. Surveillance approved June 23, 2005.

• Surveillance Procedure Manual, SP-418A, Quarterly Test of Liquid Effluent Radiation Monitor (R-15017A), Revision 21, effective April 19, 2004. Surveillance approved September 9, 2005.

• Surveillance Procedure Manual, SP-488A, Refueling Interval Calibration of Liquid Effluent Radiation Monitor (R-15017A), Revision 16, effective March 9, 2005.

Surveillance approved March 10, 2005.

• Surveillance Procedure Manual, SP-524, Quarterly Test of Plant Waste Water Flow Rate Indicator and Totalizer FIRQ-95108, Revision 17, effective November 3, 2004.

Surveillance approved June 1, 2005.

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• Surveillance Procedure Manual, SP-533, Quarterly Test of Retention Basin Discharge Flow Loop, Revision 1, effective March 25, 1997. Surveillance approved July 28, 2005.

• Surveillance Procedure Manual, SP-945, Monthly Radioactive Effluent Sampling Surveillance, Revision 8, effective October 26, 2004. Surveillance approved July 11, 2005.

• Surveillance Procedure Manual, SP-945, Monthly Radioactive Effluent Sampling Surveillance, Revision 8, effective October 26, 2004. Surveillance approved August 9, 2005.

• Surveillance Procedure Manual, SP-945, Monthly Radioactive Effluent Sampling Surveillance, Revision 8, effective October 26, 2004. Surveillance approved September 7, 2005.

• Surveillance Procedure Manual, SP-950, Weekly Liquid Holdup Tank 10 Ci Limit Surveillance, Revision 4, effective November 5, 2003. Surveillance approved September 13, 2005.

• Surveillance Procedure Manual, SP-950, Weekly Liquid Holdup Tank 10 Ci Limit Surveillance, Revision 4, effective November 5, 2003. Surveillance approved September 19, 2005.

• Surveillance Procedure Manual, SP-950, Weekly Liquid Holdup Tank 10 Ci Limit Surveillance, Revision 4, effective November 5, 2003. Surveillance approved September 26, 2005.

Procedures

• Radwaste Control Manual RP.309.I.03, Radioactive Waste Classification and Waste Form, Revision 10, effective August 1, 2005.

• Radwaste Control Manual RP.309.I.12, Reactor Vessel Internals Packaging Plan, Revision 1, effective September 29, 2005.

• Radwaste Control Manual RP.309.III.03, Radiologically Controlled Vacuum Cleaners, Revision 5, effective January 10, 2005.

• Radwaste Control Manual RP.309.IV.01, IOS Building Operations, Revision 5, effective April 27, 2005.

Reports

• Rancho Seco Training Information Management System, Employee Report Card, Coder, Richard S., for CY 2003, 2004, and 2005 as of November 16, 2005.

• Rancho Seco Training Information Management System, Employee Report Card, Gonzales, David G., for CY 2003, 2004, and 2005 as of November 16, 2005.

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• Rancho Seco Training Information Management System, Employee Report Card, Johnson, Karl C., for CY 2003, 2004, and 2005 as of November 16, 2005.

• Rancho Seco Training Information Management System, Employee Report Card, LeVan, Dennis W., for CY 2003, 2004, and 2005 as of November 16, 2005.

• Rancho Seco Training Information Management System, Employee Report Card, Tapia, Raynaldo L., for CY 2003, 2004, and 2005 as of November 16, 2005.

• Rancho Seco Training Information Management System, Employee Report Card, Thompson, Dennis L., for CY 2003, 2004, and 2005 as of November 16, 2005.

• Deviation from Quality Report DQ # 05-0014, Individual entered Secured Hi-Rad area w/out RP coverage, final review September 19, 2005.

• Deviation from Quality Report DQ # 05-0018, Discharge line from polishing Demin sump to Retention Basin was damaged during dismantlement, date identified November 1, 2005.

• Deviation from Quality Report DQ # 05-0019, RS-RVI-019 Liner Over-Pack dented on top, date identified November 3, 2005.

Other Documents

• Mike Snyder and Jerry Delezenski, DPT 05-023, Signature Authority for Radioactive Shipments, dated March 10, 2005.

• Reactor Vessel Internals Cutup/Packing Status as of: 10-31-05.

• Watts Happening, October 24, 2005 issue.

• Watts Happening, October 31, 2005 issue.