IR 07200011/2025001
| ML25346A046 | |
| Person / Time | |
|---|---|
| Site: | 07200011 |
| Issue date: | 12/15/2025 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Ed Miller Rancho Seco Assets Power Generation |
| Brookhart L | |
| References | |
| IR 2025001 | |
| Download: ML25346A046 (0) | |
Text
December 15, 2025
SUBJECT:
RANCHO SECO INDEPENDENT SPENT FUEL STORAGE INSTALLATION -
NRC INSPECTION REPORT 07200011/2025001
Dear Ernie Miller:
On September 16-18, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your independent spent fuel storage installation (ISFSI) at the Rancho Seco facility. On December 1, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The inspection results are documented in the enclosure report.
Based on the results of this inspection, the NRC has determined one Severity Level IV violation of NRC requirements occurred. Because Rancho Seco initiated a condition report to address this issue, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described in the subject inspection report.
If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: (1) the Regional Administrator, Region IV; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedures, a copy of this letter, its enclosure, and your response if you choose to provide one will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction. If you have any questions regarding this inspection report, please contact Lee Brookhart at 817-200-1549, or the undersigned at 817-200-1249.
Sincerely, Jeffrey E. Josey, Chief Decomm., ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket No. 072-00011 License No. SNM-2510 Enclosure:
Inspection Report 072-00011/2025-001 with Attachment, Rancho Seco Request for Information Signed by Josey, Jeffrey on 12/15/25
SUNSI Review By: LEB
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE SSFSI:DRSS/DIOR RI:DORS/PBB TA:DRSS C:DRSS/DIOR NAME LBrookhart JFreeman BTharakan JJosey SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE 12/15/25 12/15/25 12/12/25 12/15/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Nos.
072-00011
License Nos.
Report Nos.
07200011/2025001
Enterprise Identifiers: I-2025-001-0129
Licensee:
Sacramento Municipal Utility District (SMUD)
Facility:
Rancho Seco Facility and
Independent Spent Fuel Storage Installation
Location:
Herald, California
Inspection Dates:
September 16-18, 2025
Inspectors:
L. Brookhart, Senior Spent Fuel Storage Inspector
J. Freeman, ISFSI and Reactor Inspector
B. Tharakan, CHP, Reactor and Health Physics Inspector
Approved By:
J. Josey, Chief
Decommissioning, ISFSI, Operating Reactor Branch
Division of Radiological Safety and Security
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) conducted an announced, routine inspection of the operations and activities at the Rancho Seco independent spent fuel storage installation (ISFSI) located in Herald, California.
List of Findings and Violations
Failure to implement Aging Management Program Severity Level IV NCV 07200011/2025001-01 Open/Closed Report Section: IP 60859, Section 03.02 The inspectors identified a Severity Level IV, non-cited violation (NCV) of NRC SNM-2510 License Condition 21 for the licensees failure to implement the activities in the aging management programs (AMPs) described in the renewed license's updated Final Safety Analysis Report (FSAR). The inspectors identified four examples of AMP activities that were not completed, within the required timelines, as specified by FSAR requirements.
Additional Tracking Items
None.
SITE STATUS The Rancho Seco ISFSI was loaded with 22 dry shielded canisters (DSCs) based on the Standardized NUHOMS 24P - DSC design. These DSCs are stored in Orano TransNuclear (TN) Horizontal Storage Modules (HSMs). Twenty-one of the DSCs contain 493 spent fuel assemblies stored at the ISFSI, and one DSC contains reactor related greater than class C (GTCC) waste. The ISFSI is maintained under a site specific NRC 10 CFR Part 72 license. The canisters containing spent fuel were loaded using SNM-2510 License Amendment 0 and FSAR,
Revision 1 and 2. The GTCC canister was loaded using SNM-2510 License Amendment 2 and FSAR Revision 3. The site currently maintains the ISFSI in accordance with SNM-2510 License Amendment 4 Renewed and FSAR Revision 11.
INSPECTION SCOPES
The inspection was conducted using inspection procedures (IPs) 60858 and 60859. Currently approved IPs are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess the licensees performance and compliance with the Commissions rules and regulations, ISFSI certificate of compliance, license conditions, site procedures, and standards. The inspection was declared complete when the objectives of the IP were met, consistent with Inspection Manual Chapter (IMC) 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-Than-Class C Waste at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 Transportation Packaging, dated October 16, 2024.
IP 60858 - Away-From-Reactor ISFSI Inspection Guidance The inspectors conducted site tours, interviewed site staff, and reviewed selected records to observe the status of the ISFSI and ISFSI operations.
Changes, Tests, and Experiments and 72.212 Evaluations (IP Section 02.01)
The inspectors:
- (1) Reviewed the licensees changes, tests, or experiments that were performed by the licensee under the sites 10 CFR 72.48 program since the last NRC inspection
- (2) Reviewed the licensees changes to the sites FSAR, which included the changes from revision 9 to revision 11 Radiation Protection Program (IP Section 02.02)
The inspectors:
- (1) Reviewed quarterly radiological surveys in and around the ISFSI area
- (2) Conducted a site walkdown and verified the radioactive material present at the ISFSI was properly controlled and stored in accordance with site requirements
- (3) Verified radioactive material and areas were properly posted in accordance with 10 CFR Part 20 requirements Emergency Preparedness Program (IP Section 02.03)
The inspectors:
- (1) Reviewed site evaluations for licensee changes made to the emergency plan (EP) since the last NRC inspection
- (2) Verified the EP changes implemented in revision 3 and revision 4 did not decrease the overall effectiveness of the EP
- (3) Reviewed records of EP biennial exercises, EP drills, and EP audits Maintenance and Surveillance Program (IP Section 02.04)
The inspectors:
- (1) Reviewed records for compliance with technical specifications for operational surveillance activities and FSAR required annual maintenance activities
- (2) Performed walkdown to assess the overall material condition of the ISFSI to ensure safe operation of the ISFSI
- (3) Verified by direct observation combustible materials were properly controlled and in compliance with the sites fire hazards analysis Environmental Monitoring Program (IP Section 02.05)
The inspectors:
- (1) Reviewed environmental operating reports for radiological dose at the owner-controlled boundary to verify compliance with the requirements of 10 CFR 72.104 for years 2021-2024 Quality Assurance Program (IP Section 02.06)
The inspectors:
- (1) Reviewed selected ISFSI-related condition reports issued since the last NRC ISFSI inspection
- (2) Reviewed quality assurance program implementation, including recent audits, surveillances, receipt inspection, and quality control activities related to ISFSI operations Aging Management Activities (IP Section 02.07)
The licensee had entered the period of continuing operations for the ISFSI, beyond the original 20-year license. The inspectors utilized Inspection Procedure 60859 to review the licensees implementation of aging management activities.
IP 60859 ISFSI License Renewal Inspection For Rancho Seco, the 20-year original ISFSI license period ended June 30, 2020. On March 9, 2020, Rancho Seco received a 40-year license renewal for the ISFSI from the NRC.
The SNM-2510 ISFSI License Amendment 4 Renewed has an expiration date of midnight on June 30, 2060. The renewed license Condition 21 established a deadline to perform the ISFSIs aging management baseline inspections prior to the FSAR requirement of June 30, 2022.
General Inspection (IP Section 03.01)
The inspectors:
- (1) Reviewed aging management ISFSI-related condition reports
- (2) Reviewed quality assurance program implementation of aging management activities, including properly calibrated equipment, document control, receipt inspection, and design control of the aging management program and procedures
- (3) Reviewed training records and certificates of the qualified individuals that performed the baseline inspections to verify compliance with American Society of Mechanical Engineers (ASME)Section XI, Article IWA-2200 for VT-3 examinations or American Concrete Institute (ACI) requirements for concrete inspections.
Specific Inspection Requirements (IP Section 03.02)
The inspectors:
- (1) Inspectors performed a comprehensive review of the Rancho Seco renewed license amendment 4, NRC staff evaluation, FSAR changes, licensee's aging management program, implementing procedures, and reviewed results from the sites baseline inspections.
- (2) Besides what is described below in the Inspection Results, for each of the aging management program and their prospective procedures, the inspectors verified the licensee incorporated all applicable systems, structures, and components important to safety, correctly directed the parameters that required monitoring or inspection, contained the correct frequencies of inspection, and correct number of samples.
- (3) The procedures directed the proper acceptance criteria utilizing the correct equipment and/or processes in accordance with the applicable code requirements.
- (4) Inspectors verified the implementing procedures directed issues that did not meet acceptance criteria required by the FSAR be placed into the corrective action program for evaluation and directed results of the inspections be placed in an industry operating experience database.
- (5) Reviewed the licensees first tollgate assessment.
INSPECTION RESULTS
NRC Identified NCV Failure to implement Aging Management Program Report Section 03.02 Severity Level IV NCV 07200011/2025001-01 Open/Closed IP 60859 The inspectors identified a Severity Level IV, non-cited violation (NCV) of NRC SNM-2510 License Condition 21 for the licensees failure to implement the activities in the aging management programs (AMPs) described in the renewed license's updated Final Safety Analysis Report (FSAR). The inspectors identified four examples of AMP activities that were not completed, within the required timelines, as specified by FSAR requirements.
Description:
Rancho Seco FSAR, Volume 1, Section 9.8 titled Aging Management, described the aging management activities the licensee proposed as part of the renewed license application process and were approved by the NRC in SNM-2510 Renewed License Amendment 4. The licensee completed AMP baseline inspections prior to the established deadline of June 30, 2022. The site conducted baseline inspections in February 2022. However, the inspectors identified four examples of the licensees failure to meet requirements established in Section 9.8 of the FSAR.
- (1) FSAR Section 9.8, Table 9.8-9 required the licensee to visually inspect one DSC and listed many areas that were required to be inspected on the DSC. During the sites baseline inspections, the licensee adequately inspected the DSC shell bottom, the welds and heat affected zones (HAZs) of the shell, crevice locations near the DSC support rails, and upper surfaces of the DSC shell. The areas the licensee failed to inspect per the FSAR Table included: 1.) portions of the outer top cover plate (welds and HAZ), and 2.) outer bottom cover plate, grapple ring assembly, shear key, and bottom plate closure welds/HAZs.
- (2) Table 9.8-10 required all HSMs external concrete to be inspected (front, back, side walls, roof exterior, and HSM access door). However, the licensee only adequately inspected 1 HSM during their baseline inspections (HSM #20) and 1 shield wall, not all the HSMs and shield walls as required.
- (3) Table 9.8-12 required the accessible portions of the HSM basemat concrete to be inspected. However, the licensee only adequately inspected the accessible portions around HSM #20, not all the accessible areas of the basemat as required.
- (4) FSAR Chapter 9 states the licensee would ensure that the operation and maintenance, which includes aging management activities, would be performed in accordance with their Quality Assurance program. However, it was identified that not all the records associated with the sites baseline inspections were properly controlled and retrievable.
Corrective Actions: The licensee placed these issues into their corrective action program. The licensee is working with the cask system vendor to reschedule and reperform the sites baseline inspections to complete all required inspections and update the records.
Corrective Action Reference: PDQ 25-17
Analysis:
Consistent with guidance in the NRC Enforcement Manual, Part 1, section 1.2.6.D, if a violation does not fit an example in the Enforcement Policy violation examples, it should be assigned a severity level:
- (1) commensurate with its safety significance; and
- (2) informed by similar violation addressed in the violation examples. The inspectors determined that the violation was similar to Section 6.1.d.1 of the Enforcement Policy as a Severity Level IV violation. The violation was of very low safety significance since completed baseline inspection results did not identify any significant issues and the licensee plans to reperform the baseline inspection to complete all required actions.
Enforcement:
Severity: This issue was determined to be a Severity Level IV violation based on NRC Enforcement Policy Example 6.1.d.1.
Violation: License SNM-2510 License Condition 21 requires, in part, the licensee shall implement the activities in the AMP described in the FSAR.
Contrary to the above, prior to June 30, 2022, the licensee failed to implement all required AMP baseline inspection activities as described in the FSAR. Specifically, Rancho Seco failed to inspect all required locations of the DSC, all HSMs exteriors, all accessible areas of the ISFSI basemat, and adequately utilize the sites QA program to properly control inspection related documents.
Enforcement Action: This violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETING/DEBRIEFS The inspectors verified that no proprietary information was retained or documented in this report.
- On December 1, 2025, the inspectors presented the final exit meeting to Ernie Miller, Manager Rancho Seco Assets, and other members of the licensees staff.
ADDITIONAL
DOCUMENTS REVIEWED
None.
ATTACHMENT
Rancho Seco ISFSI Inspection Request for Information
Request for Information
Triennial Inspection of an ISFSI Operations
2-00011/2025-001
Inspection Report:
Stand Alone Report issued 30 days after exit
Inspection Dates:
Week September 15th
Inspection Procedure:
IP 60858, Triennial, AFR ISFSI inspection
IP 60859, one-time, ISFSI license renewal inspection
Inspector(s):
Lee Brookhart, Senior ISFSI Inspector, Lead
Jack Freeman, ISFSI Inspector
Binesh Tharakan, HP/Reactor inspector
The following is an initial list of information and documents needed for the September 2025
ISFSI inspection. Please provide the requested information to the NRC using IMS Certrec or
other electronic means available. If possible, please provide the requested documents 1-2
weeks prior to the on-site inspection to allow inspectors the time to review the information. All
documents that are provided will be shredded after the inspection report has been issued or you
can delete from Certrec or cloud service after the report has been issued. The last time NRC
was on-site for an ISFSI inspection was in February 2021.
PAPERWORK REDUCTION ACT STATEMENT
This letter contains voluntary information collections that are subject to the Paperwork Reduction Act of 1995 (44
U.S.C. 3501 et seq.). The Office of Management and Budget (OMB) approved these information collections
(approval number 3150-0011). The burden to the public for these information collections is estimated to average 90
hours per response. Send comments regarding this information collection to the FOIA, Library and Information
Collection Branch, Office of the Chief Information Officer, Mail Stop: t6-A10M, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and to the Desk Officer,
Officer of Information and Regulatory Affairs, NEOB-10202, (3150-0011) OMB, Washington, DC 20503.
Please make the following available:
IP 60858 - AFR ISFSI Inspection documentation:
1.
Copies of ISFSI QA related audits since February 2021.
2.
Copies of ISFSI QA surveillances conducted (if, any) since February 2021.
3.
List of ISFSI related condition reports since February 2021. We will review the list and
request selected CRs for further review.
4. Provide a copy of your corrective action program procedure, also the procedure that
discusses the different significance levels of the CRs placed into the CAP program at
Rancho Seco.
5.
List of ISFSI related modifications/72.48 screenings since February 2021 We will review the
list and request selected 72.48 screenings for review. This is mostly looking for screens
associated with engineering changes, equipment changes, or 72.48 screens for procedure
revisions. Since other sites have had problems providing us with a list of screenings, we
can talk about the kind of list we are looking for to minimize your effort to generate the list.
6. Provide a copy of your 72.48 screening/evaluation procedure.
7.
Copies of 72.48 full evaluations performed since February 2021.
8. Copies of 72.48 screens for FSAR revision changes since February 2021. FSAR Revision 9
was what was reviewed last inspection.
9.
Copy of the latest radiological survey of the ISFSI pad/fence area.
10. TLD Data. Provide environmental reports for 2021, 2022, 2023, and 2024 that reflects the
dose coming from the ISFSI. We are also interested in any additional data that reflect the
ISFSI dose such as TLDs that may be posted on the ISFSI fence or around the ISFSI that
are not listed in the environmental report.
11. Provide a copy of your current Emergency Plan. In the last inspection, RS was on
Revision 2. Please provide any changes and the effectiveness review of changes that have
been performed for revisions beyond Revision 2.
2. Provide a list of Emergency Plan Drills that have been performed since February 2021, we
will select a few from this list for additional review.
13. Provide the EP Exercises that have been performed since February 2021.
14. Provide training records that demonstrate that all assigned emergency response personnel
are current with training.
15. Technical Specification 5.5.3 daily/temperature monitoring vent inspections, we would like
to review documentation for weeks of June 21, 2021, September 19, 2022, February 20,
23, and July 22, 2024.
Aging Management Documentation Request.
16. Provide any SER/FSAR commitment changes or Aging Management changes that were
completed after renewed license had been issued
17. Provide any plans or processes related to the PEO to continuously incorporate operating
experience into license renewal activities.
18. For all Non-Destructive Examinations (NDE) credited for aging management activities:
a. Provide Qualification Program for Non-Destructive Examiners.
b. Provide procedure qualification and associated performance demonstration.
c. Provide procurement and equipment control procedures related to NDE.
19. Provide basis document for the selection of the loading cask.
20. AMP program documents - Provide program basis documents and administrative
procedures describing key program attributes such as program objectives, scope,
detection/monitoring methods and frequency, administrative controls, acceptance criteria,
corrective actions, and scope expansion requirements.
21. AMP procedures - Provide implementing procedures (e.g. visual examination procedure).
2. Provide work orders and or documentation associated with inspections that were completed.
23. Copies of corrective action program documents (e.g. Condition Reports) associated with the
implementation of the AMP. This includes unacceptable aging effects identified during the
implementation of baseline activities and programmatic deficiencies requiring resolution.
24. Provide description of instances where scope expansion was required based on the initial
examination.
25. Copy of evaluations performed for applicable external and internal Operating Experience
issues associated with aging management (tollgates).
26. List of AMP findings identified as a part of the AMP that the licensee reported the results of
the inspections to an operating experience database such as the Aging Management
Institute of Nuclear Power Operations Database (AMID). Procedures that control this
submittal and we will want to verify it was completed.
27. Provide processes or procedures which monitor and trend extent of aging effects and the
need for corrective or mitigative actions.
28. We may ask to review some AMP inspection video or pictures that were taken on canister
and inside of HSM. Due to size limitations on cloud servers we can work through reviewing
that documentation while on-site
If the information requested above will not be, available please contact the Lead Inspector,
listed below, as soon as possible.
Inspector Contact Information:
Jack Freeman
Senior ISFSI Inspector
Reactor and ISFSI Inspector
O: 817-200-1549
O: 817-200-1434
lee.brookhart@nrc.gov
jack.freeman@nrc.gov
Mailing Address:
- U.S. NRC, Region IV
Attn: Lee Brookhart
1600 East Lamar Blvd.
Arlington, TX 76011-4511