ML18341A172

Errata for San Onofre Nuclear Generating Station - NRC Special Inspection Report 05000206-2018-005, 05000361-2018-005, 05000362-2018-005, 07200041-2018-001 and Notice of Violation

ML18341A172
Person / Time
Site:	San Onofre
Issue date:	12/19/2018
From:	Troy Pruett Division of Nuclear Materials Safety IV
To:	Bauder D Southern California Edison Co
E. Simpson
References
EA-18-155 IR 2018005
Download: ML18341A172 (38)

See also: IR 05000206/2018005

Text

December 19, 2018

EA-18-155

Mr. Doug Bauder

Vice President and Chief Nuclear Officer

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

SUBJECT: ERRATA: SAN ONOFRE NUCLEAR GENERATING STATION - NRC SPECIAL

INSPECTION REPORT 050-00206/2018-005, 050-00361/2018-005,

050-00362/2018-005, 072-00041/2018-001 AND NOTICE OF VIOLATION

Mr. Bauder:

It was identified that the U.S. Nuclear Regulatory Commission (NRC) Special Inspection Report

No. 050-00206/2018-005, 050-00361/2018-005, 050-00362/2018-005, 072-00041/2018-001,

dated November 28, 2018 Agency Document and Management System (ADAMS) (ADAMS

Accession No. ML18332A357) and Notice of Violation (Notice) incorrectly identified the cited

violation against 10 CFR 72.192, regarding Operator training and certification program, in

lieu of citing the violation against 10 CFR 72.190, Operator requirements. The corrected

inspection report and Notice shall refer to 10 CFR 72.190 in all applicable areas. As specified

in 10 CFR 72.13, the regulation identified under 10 CFR 72.190 is applicable to a general

licensee, which is the type of license held by Southern California Edison Company. The

inspection report and all its enclosures, including the Notice, is reissued in its entirety under the

same inspection report number and is enclosed.

The change to the citation in the Notice involving training and certification of personnel does

not change the content of the inspection report, or the two apparent violations. As such, the

communications provided in the November 28, 2018, inspection report regarding your

opportunity to request a predecisional enforcement conference (PEC) or alternative dispute

resolution (ADR) remains in effect from the date of the original inspection report,

November 28, 2018. On December 10, 2018, SONGS informed the NRC that it requested a

PEC. My staff is working with your staff to schedule the PEC.

D. Bauder 2

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a

copy of this letter, its enclosures, and your response (if any), will be made available

electronically for public inspection in the NRC Public Document Room and from the NRCs

ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions concerning this matter, please contact Dr. Janine F. Katanic, CHP, of

my staff at 817-200-1151.

Sincerely,

/RA/

Troy W. Pruett, Director

Division of Nuclear Materials Safety

Docket Nos.: 50-206; 50-361; 50-362;72-041

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

Enclosure:

Revised NRC Special Inspection

Report 050-00206/2018-005,

050-00361/2018-005, 050-00362/2018-005,

and 072-00041/2018-001

ML18341A172

SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword

By: EJS Yes No Non-Sensitive Publicly Available NRC-002

OFFICE DNMS:FCDB DNMS:CFCDB D:DNMS

NAME ESimpson JFKatanic TPruett

SIGNATURE /RA/ /RA/ /RA/

DATE 12/12/18 12/18/18 12/19/18

REVISED

SAN ONOFRE NUCLEAR GENERATING STATION

NRC SPECIAL INSPECTION REPORT 050-00206/2018-005,

050-00361/2018-005, 050-00362/2018-005, 072-00041/2018-001

AND REVISED NOTICE OF VIOLATION

(ML18341A172)

Enclosure

December 19, 2018

EA-18-155

Mr. Doug Bauder

Vice President and Chief Nuclear Officer

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

SUBJECT: REVISED NRC SPECIAL INSPECTION REPORT 050-00206/2018-005,

050-00361/2018-005, 050-00362/2018-005, 072-00041/2018-001 AND REVISED

NOTICE OF VIOLATION

Mr. Bauder:

This letter refers to the Special Inspection conducted on September 10-14, 2018, at your facility

in San Clemente, California. The inspection was conducted in response to the misalignment of

a loaded spent fuel storage canister as it was being downloaded into the storage vault at the

San Onofre Nuclear Generating Station (SONGS). Based on the criteria specified in

Management Directive 8.3, NRC Incident Investigation Program, the Nuclear Regulatory

Commission (NRC) initiated a Special Inspection in accordance with Inspection

Procedure 93812, Special Inspection. The basis for initiating the Special Inspection and the

focus areas for review are detailed in the Special Inspection Charter (Enclosure 3), dated

August 17, 2018 (Agencywide Document Access and Management System (ADAMS)

Accession ML18229A203).

The enclosed report documents the results of the inspection. The inspectors discussed the

preliminary inspection findings with Mr. Thomas Palmisano and members of your staff on

September 14, 2018, at the conclusion of the onsite portion of the inspection. A final exit

briefing was conducted telephonically with Mr. Palmisano and members of your staff on

November 1, 2018.

Based on the results of the Special Inspection, two apparent violations were identified and are

being considered for escalated enforcement action in accordance with the NRC Enforcement

Policy. The current Enforcement Policy is included on the NRC Web site at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The circumstances

surrounding these apparent violations, the significance of the associated issues, and the need

for corrective actions were discussed with Mr. Palmisano at the conclusion of the onsite

inspection and during the final telephonic exit briefing. The apparent violations involved the

failure to: (1) ensure important-to-safety equipment was available to provide redundant drop

protection features for a spent fuel canister during downloading operations; and (2) make a

timely notification to the NRC Headquarters Operations Center for the August 3, 2018, disabling

of important-to-safety equipment.

D. Bauder 2

The NRC is concerned about apparent weaknesses in management oversight of the dry cask

storage operations. Your staff did not perform adequate direct observational oversight of

downloading activities performed by your contractor, ensure adequate training of individuals

responsible for performing downloading operations, provide adequate procedures for

downloading operations, or ensure that conditions adverse to quality were entered into the

corrective action program. The NRC identified that a causal factor for the misalignment incident

involved management weakness in the oversight of dry cask storage operations.

Before the NRC makes its enforcement decision, we are providing you with an opportunity to:

(1) request a predecisional enforcement conference (PEC) or (2) request alternative dispute

resolution (ADR). If a PEC is held, it will be open for public observation and the NRC will issue

a press release to announce the time and date of the conference.

If you choose to request a PEC, the conference will afford you the opportunity to provide your

perspective on these matters and any other information that you believe the NRC should take

into consideration before making an enforcement decision. The decision to hold a PEC does

not mean that the NRC has determined that a violation has occurred or that enforcement action

will be taken. This conference would be conducted to obtain information to assist the NRC in

making an enforcement decision.

The topics discussed during the conference may include information to determine whether a

violation occurred, information to determine the significance of a violation, information related to

the identification of a violation, and information related to any corrective actions taken or

planned. In presenting your corrective actions, you should be aware that the promptness and

comprehensiveness of your actions will be considered in assessing any civil penalty for the

apparent violations. The guidance in NRC Information Notice 96-28, Suggested Guidance

Relating to Development and Implementation of Corrective Action, may be helpful and can be

obtained at the NRC Web site at http://pbadupws.nrc.gov/docs/ML0612/ML061240509.pdf.

In lieu of a PEC, you may also request ADR with the NRC in an attempt to resolve this issue.

Alternative dispute resolution is a general term encompassing various techniques for resolving

conflicts using a neutral third party. The technique that the NRC has decided to employ is

mediation. Mediation is a voluntary, informal process in which a trained neutral mediator works

with parties to help them reach resolution. If the parties agree to use ADR, they select a

mutually agreeable neutral mediator who has no stake in the outcome and no power to make

decisions. Mediation gives parties an opportunity to discuss issues, clear up

misunderstandings, be creative, find areas of agreement, and reach a final resolution of the

issues.

Additional information concerning the NRCs program can be obtained at

http://www.nrc.gov/about-nrc/regulatory/enforcement/adr.html. The Institute on Conflict

Resolution at Cornell University has agreed to facilitate the NRCs program as a neutral third

party. Please contact the Institute on Conflict Resolution at 877-733-9415 within 10 days of the

date of this letter if you are interested in pursuing resolution of these issues through ADR.

Alternative dispute resolution sessions are not conducted with public observation though the

outcome of the ADR agreement is made public.

A PEC should be held within 30 days and an ADR session within 45 days of the date of this

letter. Please contact Dr. Janine F. Katanic at 817-200-1151 within 10 days of the date of this

letter to notify the NRC of your intended response.

D. Bauder 3

In addition, please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review.

You will be advised by separate correspondence of the results of our deliberations on this

matter.

The NRC determined that three Severity Level IV violations of NRC requirements occurred.

These violations were evaluated in accordance with Section 2.2.2 of the NRC Enforcement

Policy. The NRC determined the issuance of a Notice of Violation (Notice) is appropriate

because the actions to restore compliance have not been fully developed and implemented,

and the actions must be effective prior to beginning fuel handling activities.

The three Severity Level IV violations are cited in the enclosed Notice and the circumstances

surrounding them are described in detail in the subject inspection report. The violations

involved failures to: (1) identify conditions potentially adverse to quality for placement into your

corrective actions program; (2) assure that operations of important to safety equipment were

limited to trained and certified personnel or under direct supervision; and (3) provide adequate

procedures for dry cask storage operations involving downloading operations.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a

copy of this letter, its enclosures, and your response, will be made available electronically for

public inspection in the NRC Public Document Room and from the NRCs ADAMS, accessible

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible,

your response should not include any personal privacy or proprietary information so that it can

be made available to the public without redaction.

If you have any questions concerning this matter, please contact Dr. Janine F. Katanic, CHP, of

my staff at 817-200-1151.

Sincerely,

/RA/

Troy W. Pruett, Director

Division of Nuclear Materials Safety

Docket Nos.: 50-206; 50-361; 50-362;72-041

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

Enclosures:

1. Notice of Violation

2. Revised NRC Special Inspection

Report 050-00206/2018-005,

050-00361/2018-005,

050-00362/2018-005, and

072-00041/2018-001

3. Special Inspection Charter dated

August 17, 2018 (ML18229A203)

NOTICE OF VIOLATION

Southern California Edison Company Docket Nos.: 050-00206, 050-00361,

San Clemente, CA 050-00362, 072-00041

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

EA No: 18-155

During an NRC Special Inspection conducted September 10 through November 1, 2018, three

violations of NRC requirements were identified. In accordance with the NRC Enforcement

Policy, the violations are listed below:

A. 10 CFR 72.172 requires, in part, that, licensees establish measures to ensure that

conditions adverse to quality, such as failures, malfunctions, deficiencies, and

deviations, are promptly identified and corrected.

Contrary to the above, from January 30 to August 3, 2018, the licensee failed to

establish measures to ensure that conditions adverse to quality, such as failures,

malfunctions, deficiencies, and deviations, were promptly identified and corrected.

Specifically:

1. On July 22, 2018, the loading crew experienced difficulty in aligning canister 28 for

downloading into the independent spent fuel installation vault. However, the licensee

failed to enter this deviation in downloading conditions into its corrective action

program to determine the cause of the misalignment problem and develop corrective

actions to preclude reoccurrence.

2. From January 30 to August 3, 2018, during canister downloading, contact between

the canister and vault components frequently occurred. However, the licensee failed

to enter instances of contact into its corrective action program and perform an

assessment to disposition the exterior conditions of the downloaded canisters and

vault components.

This is a Severity Level IV violation (NRC Enforcement Policy Section 6.3).

B. 10 CFR 72.190 requires, in part, that the operation of equipment and controls that have

been identified as important to safety in the Safety Analysis Report and in the license

must be limited to trained and certified personnel or be under the direct supervision of an

individual with training and certification in the operation. The HI-STORM UMAX

SYSTEM Final Safety Analysis Report (FSAR), Revision 4, dated August 14, 2017,

specifies, in part, that the operations at the independent spent fuel storage installation

are governed by the HI-STORM FW SYSTEM FSAR, Revision 5, dated June 20, 2017,

which specifies that the multipurpose canister lifting slings and multipurpose canister lift

attachments are designated as important to safety equipment.

Contrary to the above, from January 30 to August 3, 2018, the licensee failed to assure

that operations of equipment and controls that had been identified as important to safety

in the Safety Analysis Report were limited to trained and certified personnel or were

under the direct supervision of an individual with training and certification in the

operation. Specifically:

Enclosure 1

1. The training program failed to adequately train and certify the rigger/spotter position

involved in the important to safety downloading operation.

2. The training program for the vertical cask transporter operator position failed to have

adequate proficiency testing, on the controls related to the load indicating device and

downloading operations.

This is a Severity Level IV violation (NRC Enforcement Policy Section 6.3).

C. 10 CFR 72.150, requires, in part, that the licensee prescribe activities affecting quality by

documented instructions or procedures of a type appropriate to the circumstances and

must include appropriate quantitative or qualitative acceptance criteria for determining

that important activities have been satisfactorily accomplished.

Contrary to the above, from January 30 to August 3, 2018, the licensee failed to

prescribe activities affecting quality by documented instructions or procedures of a type

appropriate to the circumstances and include appropriate quantitative or qualitative

acceptance criteria for determining that important activities have been satisfactorily

accomplished. Specifically:

1. Procedure HPP-2464-400, Multi-Purpose Canister Transfer at SONGS,

Revision 15, step 7.6.23, failed to provide qualitative and quantitative directions for

the vertical cask transporter operator to monitor control panel indications that would

identify a canister had become misaligned during downloading operation.

2. Procedure HPP-2464-400, Multi-Purpose Canister Transfer at SONGS,

Revision 15, step 7.6.23, failed to include adequate instructions for the rigger/spotter

to monitor the downloading slings for a slack condition.

This is a Severity Level IV violation (NRC Enforcement Policy Section 6.3).

Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby

required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the

Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 1600 E. Lamar Blvd.,

Arlington, TX 76011, within 30 days of the date of the letter transmitting this Notice of Violation

(Notice).

This reply should be clearly marked as a Reply to a Notice of Violation, EA-18-155 and should

include, for each violation: (1) the reason for the violation, or, if contested, the basis for disputing

the violation or severity level; (2) the corrective steps that have been taken and the results

achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will

be achieved. Your response may reference or include previous docketed correspondence, if

the correspondence adequately addresses the required response. If an adequate reply is not

received within the time specified in this Notice, an order or a Demand for Information may be

issued requiring information as to why the license should not be modified, suspended, or

revoked, or why such other action as may be proper should not be taken. Where good cause is

shown, consideration will be given to extending the response time.

2

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory

Commission, Washington, DC 20555-0001.

Your response will be made available electronically for public inspection in the NRC Public

Document Room or in the NRCs Agencywide Documents Access and Management System

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To

the extent possible, your response should not include any personal privacy or proprietary

information so that it can be made available to the public without redaction.

If personal privacy or proprietary information is necessary to provide an acceptable response,

then please provide a bracketed copy of your response that identifies the information that

should be protected and a redacted copy of your response that deletes such information. If you

request withholding of such material, you must specifically identify the portions of your response

that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal

privacy or provide the information required by 10 CFR 2.390(b) to support a request for

withholding confidential commercial or financial information).

Dated this 19th day of December 2018

3

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-206; 50-361; 50-362;72-041

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

Report No.: 050-00206/2018005; 050-00361/2018005; 050-00362/2018005;

and 072-00041/2018001

EA No.: 18-155

Licensee: Southern California Edison Company

Location: San Clemente, CA 92674-012

Inspection Dates: Onsite September 10-14, 2018

In-office review through November 1, 2018

Exit Meeting Date: November 1, 2018

Inspectors: Eric Simpson, CHP, Health Physicist

Fuel Cycle and Decommissioning Branch

Division of Nuclear Materials Safety, Region IV

Marlone Davis, Senior Inspector

Inspections and Operations Branch

Division of Spent Fuel Management

W. Chris Smith, Reactor Inspector

Engineering Branch 1

Division of Reactor Safety, Region IV

Accompanied By: Janine F. Katanic, PhD, CHP, Chief

Fuel Cycle and Decommissioning Branch

Division of Nuclear Materials Safety, Region IV

Patricia Silva, Chief

Inspections and Operations Branch

Division of Spent Fuel Management

Troy W. Pruett, Director

Division of Nuclear Materials Safety, Region IV

Approved By: Troy W. Pruett, Director

Division of Nuclear Materials Safety, Region IV

Attachment: Supplemental Inspection Information

Enclosure 2

EXECUTIVE SUMMARY

NRC Special Inspection Report 050-00206/2018005; 050-00361/2018005;

050-00362/2018005; and 072-00041/2018-001

On September 10-14, 2018, the U.S. Nuclear Regulatory Commission performed an announced

Special Inspection of the independent spent fuel storage installation at the decommissioning

San Onofre Nuclear Generating Station in San Clemente, California. The inspection continued

with an in-office review of training material, licensee analyses, procedures, and other materials

gathered during the onsite inspection through November 1, 2018. The Southern California

Edison Company, the licensee and owner of San Onofre Nuclear Generating Station, has an

NRC General License for its independent spent fuel installation under Title 10 of the Code of

Federal Regulations (10 CFR) Part 72. The scope of the inspection was to evaluate the facts

and circumstances involved in the August 3, 2018, misalignment incident, and review the

licensees follow-up investigation, causal evaluation, and planned corrective actions.

NRC Special Inspection of San Onofre Nuclear Generating Station Canister Misalignment

Incident of August 3, 2018

• The licensees actions that led to disabling the important to safety downloading slings

and removal of redundant drop protection features were identified as an apparent

violation of Technical Specification 5.2.c.3 requirements. (Section 3.1.1)

• The NRC team identified missed opportunities where the licensee could have addressed

the potential for a downloading misalignment. For example, on July 22, 2018, one of the

crews experienced misalignment difficulty resulting in a prolonged downloading

operation. The licensee did not enter the adverse condition into the corrective action

program to determine the cause and develop appropriate corrective actions. This was

identified as a Severity Level IV violation of 10 CFR 72.172 requirements. (Section 3.1.1)

• Personnel lacked the proper training, proficiency testing, and certifications to operate

important to safety equipment identified in the HI-STORM UMAX SYSTEM Final Safety

Analysis Report, Revision 4, dated August 14, 2017. This was identified as a Severity

Level IV violation of 10 CFR 72.190 requirements. (Section 3.1.2)

• Dry cask storage procedures did not provide adequate directions for how to determine

the downloader slings were slack. Slack in the slings was an indicator of a loss-of-load.

Further, procedures did not include qualitative or quantitative means to determine when

a canister had become misaligned. These procedure inadequacies were identified as a

Severity Level IV violation of 10 CFR 72.150 requirements. (Section 3.1.3)

• No licensee or contractor oversight staff were in direct visual observation of important to

safety activities during downloading operations on August 3, 2018. Licensee oversight

was not a part of communications between the cask loading supervisor, the

rigger/spotter, and vertical cask transporter operator during downloading operations.

(Section 3.1.3)

2

• The licensee concluded and the NRC agreed that the minor removal of divider shell

coating during downloading operations did not affect the design functions for shielding,

structural, and thermal safety functions. The licensees plan to address future inspection

of the divider shells in their aging management program is acceptable. (Section 3.1.4)

• The licensee failed to make the required 24-hour NRC notification of the August 3, 2018,

incident where important to safety equipment was disabled when required to mitigate the

consequences of an accident and no redundant equipment was available to perform the

safety function. This failure was identified as an apparent violation of 10 CFR 72.75(d)

requirements. (Section 3.1.4)

• The causal evaluations performed by the licensee and its contractor identified apparent

and root causes for the August 3, 2018, canister misalignment incident that included

inadequate training, inadequate procedures, poor utilization of the corrective action

program, and insufficient management oversight. (Section 3.1.5)

• The licensees consequence analysis resulting from a hypothetical 25-foot canister drop

determined that the canister integrity would be maintained. The NRC will continue to

inspect the licensees consequence analysis. (Section 3.1.5)

• The licensee provided an analysis to demonstrate that wear on canister 29 during the

downloading incident would meet established acceptance criteria. The NRC determined

that more analysis was required to accept that the canister meets design requirements.

This charter item will be reviewed during a future NRC inspection. (Section 3.1.6)

• All associated corrective actions for the August 3, 2018, incident had not been fully

developed and implemented by the licensee. The NRC will review the licensees revised

procedures, training plans, equipment modifications, and performance testing (dry runs)

of its dry cask storage operations during a future inspection to determine the

effectiveness of corrective actions for the incident. (Section 3.1.7)

3

REPORT DETAILS

1 Inspection Scope

On September 10-14, 2018, the NRC performed an announced Special Inspection at the

San Onofre Nuclear Generating Station (SONGS) in San Clemente, California, which

was followed by in-office reviews of additional information provided by the licensee

through November 1, 2018. The scope of the inspection was to interview personnel

associated with the August 3, 2018, misalignment incident to independently evaluate the

circumstances of the canister misalignment; identify and review all pertinent records,

documents, and procedures related to the licensees downloading operations; evaluate

procedure adequacy and adherence; evaluate the reportability requirements; and to

evaluate the root cause analyses and corrective actions to prevent recurrence.

2 Background

2.1 General Description of Multi-purpose Canister Downloading Operations

On November 8, 2018, the NRC conducted a public meeting webinar (NRCs

Agencywide Documents Access and Management System (ADAMS)

Accession ML18319A139). The presentation provides a summary of a downloading

operation.

A vertical cask transporter (VCT) is used for transporting the transfer cask and

multi-purpose canister (MPC or canister) loaded with spent fuel onto the independent

spent fuel storage installation (ISFSI) pad. Dry cask storage workers manipulate the

VCT to align the transfer cask over the ISFSI vertical ventilated module (VVM or vault) in

which the canister will be stored. Once alignment has been achieved and the transfer

cask is securely bolted to a mating device, the transfer cask is disconnected from the

VCT. Lifting slings are connected to the top of the canister and the VCT overhead lift

beam. The VCT lift beam is raised until the load of the canister is supported and no

longer resting on the bottom of the transfer cask.

While the canister is being supported by the lift beam and slings, a drawer on the mating

device is opened. Once the drawer is open, the VCT operator lowers the lift beam,

which lowers the canister into the storage vault. The VCT can be moved during the

download to make fine adjustments for canister alignment within the vault. While the

canister is being lowered, it passes through a divider shell assembly. The divider shell

has a shield ring that the canister must pass through as it is being lowered into the vault.

When fully downloaded, the canister will be seated on a pedestal in the cavity enclosure

container in the vault.

2.2 August 3, 2018 Canister Misalignment

On August 3, 2018, as the loaded canister was being lowered into the vault, personnel

failed to notice that the canister was misaligned. The licensee and its contractor

continued to lower the VCT lift beam until staff believed that the canister had been fully

lowered to the bottom of the vault. Staff involved in the download failed to recognize the

lifting slings were slack. A radiation protection technician identified radiation readings

that were not consistent with a fully lowered canister. The licensee then identified that

the loaded spent fuel canister was resting on a shield ring near the top of the vault,

4

preventing it from being lowered, and that the rigging and lifting slings were slack and no

longer bearing the load of the canister.

With the slings slack, the lifting equipment was no longer capable of performing its

important to safety function of holding and controlling the loaded canister. The canister

could have experienced an approximately 17-18 foot drop into the storage vault if the

canister had slipped off the shield ring. This load drop accident is not a condition

analyzed in the dry fuel storage systems Final Safety Analysis Report (FSAR).

The licensee restored the control of the load to the slings and lifting devices. The

estimated time the canister was in an unsupported position was approximately

45 minutes. The licensee repositioned and lowered the canister into the vault. The

licensee subsequently halted all dry fuel storage movement operations in order to fully

investigate the incident and develop corrective actions to prevent recurrence.

The licensee informed Region IV staff of the misalignment incident on August 6, 2018.

Region IV discussed the licensees plans for evaluation and follow-up for the incident

and the status of fuel loading operations. The licensee agreed to suspend fuel loading

operations until such time as their senior management was satisfied with their corrective

actions, the NRC completed their inspection, and the NRC determines that corrective

actions are sufficient to prevent a similar occurrence. Region IV chartered a Special

Inspection Team to review the incident, any relevant background information, causal and

risk assessments conducted by the licensee, and proposed and completed corrective

actions.

3 Special Inspection Charter (IP 93812)

3.1 Inspection Scope

Following the notification to NRC Region IV of the August 3, 2018, misalignment

incident, the NRC evaluated the information provided against the criteria for a reactive

inspection. Based on the criteria in Management Directive 8.3, NRC Incident

Investigation Program, and Inspection Manual Chapter 0309, Reactive Inspection

Decision Basis for Reactors, a decision was made to perform a Special Inspection. The

Special Inspection Charter is provided in Enclosure 3.

The Special Inspection was conducted onsite from September 10-14, 2018, and

continued with in-office review until November 1, 2018. The Special Inspection focused

on understanding the August 3, 2018, misalignment incident. The inspection included

interviewing personnel involved in the incident, developing a timeline, and assessing the

licensees immediate corrective actions.

The sections below provide inspection details for each of the Special Inspection Charter

items.

5

3.1.1 Charter Item 5

Inspection Scope

Interview personnel associated with the August 3, 2018, misalignment incident to

develop a timeline to ensure the licensees investigation contained all necessary

information to identify all contributing factors and develop adequate corrective actions.

The NRC team interviewed licensee and contractor staff involved or present during the

August 3, 2018, misalignment incident. The NRC also reviewed records related to dry

cask storage operations.

Observations and Findings

Based on interviews and records reviewed, the following timeline was developed:

Date/Time (+/- 30 minutes) Activity

August 3, 2018

12:40 p.m. Downloading begins for canister 29:

All dry cask storage supervision and licensee oversight,

including radiation protection staff exited the ISFSI pad

to stand in a low-dose area on the ISFSI pad ramp

(approximately 150 feet away from the operations).

Only the rigger/spotter in the motor-powered boom lift

device man-basket (JLG) and the VCT operator

remained on the ISFSI pad.

1:05 p.m. VCT operator and rigger/spotter notify cask loading

supervisor (CLS) that the canister has been fully

lowered into the ISFSI vault.

1:12 p.m. The radiation protection technician (RPT) determines

radiation levels indicate that the canister was not fully

lowered.

Work activities were stopped to plan recovery actions

with the radiation protection supervisor and CLS.

The rigger in charge (RIC) began making preparations

to enter the JLG.

6

1:15 p.m. Notifications were made to Holtec management.

The RIC was escorted to the JLG by an RPT.

The RIC recognized the downloading slings were slack

and bundled on the ground near the base of the VCT.

1:33 p.m. The RIC observed the top of the canister was about

4 feet from the top of the transfer cask and not lowered

into the vault.

The RIC directed the VCT operator to lift the canister.

1:41 p.m. The canister load was fully supported by the VCT and

downloading slings.

1:50 p.m. An alternate CLS arrived and began to direct operations

for downloading to the VCT operator.

The alternate CLS and RIC noted that during

downloading operations the canister experienced

interference twice and had to be re-aligned.

2:22 p.m. Downloading operations completed.

6:00 p.m. Licensee places hold on all lifting operations.

August 6, 2018 At approximately 4 pm (CDT), the licensee informally

contacted NRC Region IV to discuss the

August 3, 2018, misalignment incident.

August 7, 2018 NRC Region IV and licensee management agreed that

ISFSI operations would cease until the NRC performed

an inspection and reviewed the licensees corrective

actions to resume work.

September 14, 2018 At 4 pm (ET) the licensee made a formal notification per

10 CFR 72.75(d)(1) to the NRC Headquarters

Operations Center regarding the August 3, 2018,

misalignment incident.

Violation of 10 CFR 72.172, Corrective Actions

Interviews with Williams Industrial Services Group and Sonic Systems (Holtec

International subcontractors) employees indicated that of a loss-of-load condition or a

canister misalignment issue was experienced during dry run evolutions and known to

several dry cask storage workers. The Special Inspection team identified a prior canister

misalignment issue that occurred on July 22, 2018, in which downloading operations

lasted 90 minutes, instead of the expected 15 minutes for downloading canister 28. This

incident was documented in a Production Traveler. A Production Traveler is a document

that the licensee uses to track the performance of dry fuel storage operations by the

7

contractor, Holtec International. The Production Travelers were used to track how well

the contractor was providing their contracted services to the licensee. The licensee did

not enter this condition adverse to quality into its corrective action program.

Licensee oversight generally waited for Holtec staff to initiate a field condition report

(FCR) before writing a corresponding condition report. In the Production Traveler for

canister 28, the 90 minute delay was related to adjustments that were needed for the

VCT towers as canister weight started to lower prematurely before the downloading was

complete. This type of misalignment also occurred during the August 3, 2018, incident.

On July 22, 2018, the downloading crew for canister 28, noted the reduction in the

canister weight and corrected the alignment error. The canister was never unsupported

by the slings. No condition report or FCR was generated by either the licensee or

contractor.

Through interviews with licensee and contractor staff, the NRC determined that between

January 30 and August 3, 2018, the downloading activity often involved contact between

the canister and other vault components during downloading. The licensee and its

contractor did not enter the misalignment and contact events into the corrective action

program. Consequently, actions to assess and disposition the exterior conditions of the

downloaded canisters and other components within the vault, such as the divider shell

assembly, were not performed. The licensee is responsible to ensure the important to

safety components continue to meet their original design criteria and address any aging

management concerns the changes could impact. Any deviations, such as scratches or

removal of coatings are required to be evaluated to ensure the deviations are not

detrimental to the system.

Interviews with individuals involved in dry cask loading operations in August 2018,

revealed that the difficulty in aligning the canister was not shared with others, nor was it

incorporated into procedures or formal training programs. The VCT operator and the

rigger/spotter in charge of downloading operations during the August 3, 2018, incident

indicated that they did not know until afterwards that the condition they experienced was

something that should have been anticipated.

Title 10 CFR 72.172 requires, in part, that, licensees establish measures to ensure that

conditions adverse to quality, such as failures, malfunctions, deficiencies, and deviations

are promptly identified and corrected. Contrary to the above, the licensee failed to

establish measures to ensure that conditions adverse to quality, such as failures,

malfunctions, deficiencies, and deviations were promptly identified and corrected.

Specifically:

1. On July 22, 2018, the crew experienced difficulty in aligning canister 28 for

downloading into the ISFSI vault. However, the licensee failed to enter this

deviation in downloading conditions into its corrective action program to

determine the cause of the misalignment problem and develop corrective actions

to preclude reoccurrence.

2. From January 30 to August 3, 2018, during canister downloading, contact

between the canister and the vault components frequently occurred. The

licensee failed to enter instances of contact into its corrective action program and

perform an assessment to disposition the exterior conditions of the downloaded

canisters and vault components.

8

The team determined that this violation was more than minor because the failure to

implement corrective actions contributed to the misalignment incident of August 3, 2018.

Additionally, the failure to evaluate and disposition wear marks on a canister, if left

uncorrected, could impact the adequacy of the aging management program. The

Special Inspection team assessed and dispositioned this violation in accordance with

Section 2.2.2 of the NRC Enforcement Policy. The team characterized the violation as a

Severity Level IV violation. The NRC determined the issuance of a Notice is appropriate

because the actions to restore compliance have not been fully developed and

implemented, and the actions must be effective prior to beginning fuel handling activities.

(VIO 07200041/2018-001-01, Failure to identify and correct conditions adverse to

quality)

Apparent Violation of Technical Specification 5.2.c.3, Redundant Lifting

Equipment

On August 3, 2018, the licensee performed operations involving movement of a loaded

spent fuel storage canister into its ISFSI vault. As the loaded spent fuel canister was

being lowered into the vault, licensee and contractor personnel failed to notice that the

canister was misaligned and the weight of the canister was not being supported by the

redundant important to safety slings (See Sections 2.1 and 2.2).

Title 10 CFR 72.212(b)(3) requires, in part, that each cask used by the general licensee

conforms to the terms, conditions, and specifications of a Certificate of Compliance listed

in 10 CFR 72.214. Title 10 CFR 72.214 includes a list of all the approved spent fuel

storage casks that can be utilized under the conditions specified in a specific Certificate

of Compliance, including Amendment 2 of Certificate of Compliance 072-01040.

Certificate of Compliance 072-01040, Amendment 2, Condition 4, HEAVY LOADS

REQUIREMENTS, requires that lifting operations outside of structures governed

by 10 CFR Part 50 must be in accordance with Technical Specifications, Appendix A,

Section 5.2.

Technical Specification, Appendix A, Section 5.2.c.3 requires that the transfer cask,

when loaded with spent fuel, may be lifted and carried at any height during multi-purpose

canister transfer operations provided the lifting equipment is designed with redundant

drop protection features which prevent uncontrolled lowering of the load.

Contrary to the above, on August 3, 2018, the licensee failed to ensure that redundant

drop protection features were available to prevent uncontrolled lowering of the load.

Specifically, the licensee inadvertently disabled the redundant important to safety

downloading slings while lowering canister 29 into the storage vault. During the

approximately 45 minute time-frame, the canister rested on a shield ring unsupported by

the redundant downloading slings at approximately 17-18 feet above the fully seated

position. This failure to maintain redundant drop protection placed canister 29 in an

unanalyzed condition because the postulated drop of a loaded spent fuel canister is not

analyzed in the FSAR.

The licensees failure to ensure the systems designed redundant drop protection

features were available to prevent uncontrolled lowering of the loaded canister was

identified as an apparent violation of Technical Specification 5.2.c.3.

(AV 07200041/2018-001-02, Failure to ensure redundant drop protection features are

available)

9

Conclusions

The licensee failed to adequately implement the corrective action program for ISFSI

operations. This failure resulted in missed opportunities to resolve misalignment errors

during canister downloading operations between January 30 and August 3, 2018, and a

violation of 10 CFR 72.172.

On August 3, 2018, the licensee failed to recognize that a misalignment of a canister

during downloading operations caused redundant drop protection (slings) to be disabled

and an apparent violation of Technical Specification 5.2.c.3.

3.1.2 Charter Item 1

Inspection Scope

Identify and review all pertinent records, documents, and procedures related to the

licensees downloading operations at the ISFSI pad including but not limited to: worker

training and qualifications; rigging equipment qualification, testing, and preventative

maintenance; and lifting equipment qualification, testing, and preventative maintenance.

Evaluate the adequacy of the above noted procedures, worker training, and equipment

testing and preparation.

The Special Inspection team reviewed licensee rigging procedures and NUREG-0612

Control of Heavy Loads at Nuclear Power Plants, training modules. The team

reviewed the qualifications for the dry cask storage workers including the records for the

workers involved in the August 3, 2018, misalignment incident. The team reviewed the

inspection and maintenance records for special lifting devices used during dry fuel

storage operations and the qualification records for rigging equipment. The team

reviewed procedures used during canister downloading operations.

Observations and Findings

The equipment used for dry cask storage operations met applicable inspection

requirements specified in the Holtec HI-STORM UMAX FSAR. The special lifting

devices used to transport the transfer cask and to perform downloading operations were

designed and tested according to American National Standards Institute (ANSI) N14.6,

American National Standard for Radioactive Materials - Special Lifting Devices for

Shipping Containers Weighing 10,000 Pounds or More. The slings used during

downloading had a sufficient load rating for the maximum credible load imposed by the

canister. The slings were tested according to the safety requirements of American

Society of Mechanical Engineers (ASME) B30.9, Slings. The purchase specifications,

qualifications, and maintenance records for the VCT, downloading slings, canister lift

cleats, lift lugs, and lift links were satisfactory.

Violation of 10 CFR 72.190, Training and Certification Qualifications

The NRC team reviewed the qualifications of workers involved in the August 3, 2018,

incident. Interviews with the individuals primarily responsible for verifying that the

canister was properly downloaded into the ISFSI vault showed that the licensees

training program was inadequate for the positions that are designated as rigger/spotter

and VCT operator. The VCT operator training program qualifications did not establish

10

adequate required proficiency training exercises for downloading operations. The VCT

operator on August 3, 2018, had never been tested on or exercised with the canister

simulator during a pre-operational testing, dry run downloading operation. The

August 3, 2018, misalignment incident was the first time the VCT operator had actually

completed downloading operations as the VCT operator.

Neither the rigger/spotter nor VCT operator was properly trained in determining a

loss-of-load condition during downloading operations. The VCT operator stated that he

was knowledgeable of the VCT human-machine interface (HMI) screens and that

indications provided a digital reading that could allow the operator to determine if the

canister was not supported by the slings. However, the VCT operator stated that he did

not use the VCT HMI screen to monitor the load of the canister at any time during the

August 3, 2018, downloading operations. The VCT operator indicated that he only

utilized the HMI screen to determine how evenly the VCT lift beam was descending.

From his position on the VCT, the VCT operator could not see the canister downloader

slings. The only indication of a loss-of-load would come from monitoring the VCT

hydraulic beam pressure digital reading on the VCT HMI screen, which was not

performed. Since the operator had not performed any proficiency training with the VCT

during a dry run downloading operation, the individual was inexperienced with the use of

the HMI screen to monitor load loss.

The licensees training program did not provide a formal process to be qualified for the

rigger/spotter position during downloading operations. The rigger/spotter stated that he

was not trained on and did not know his roles and responsibilities during the

downloading evolution. The August 3, 2018, misalignment incident was the first time the

rigger/spotter had attempted to perform downloading operations as the rigger/spotter in

the JLG.

The NRC teams interview with the foreman indicated that the rigger/spotter was

selected primarily because of his low accumulated radiation dose. From interviews with

licensee and contractor staff, an experienced RIC was usually the individual placed in

the JLG and acted as the rigger/spotter for the downloading operations. On

August 3, 2018, it was the RIC who eventually entered the JLG after the misalignment

and directed the VCT operator to lift the canister with the VCT lift beam to regain the

load on the slings. The RIC had immediately recognized that the canister was not

downloaded into the ISFSI vault when he arrived and saw the condition of the

downloader slings.

The failure to ensure operators are adequately qualified and proficiency tested when

operating important to safety equipment and directing critical lift operations is a

performance deficiency. The licensees training program that allowed the rigger/spotter

and VCT operator to be placed into a situation where their lack of training rendered them

incapable of meeting the requirements for the job represented a failure of the licensees

training program.

Title 10 CFR 72.190 requires, in part, that the operation of equipment and controls that

are identified as important to safety in the Safety Analysis Report must be limited to

trained and certified personnel or be under the direct supervision of an individual with

training and certification in the operation. The HI-STORM UMAX SYSTEM FSAR,

Revision 4, dated August 14, 2017, specifies, in part, that the operations at the ISFSI are

11

governed by the HI-STORM FW SYSTEM FSAR, Revision 5, dated June 20, 2017,

which specifies that the MPC lifting slings and MPC lift attachments are designated as

important to safety equipment. Contrary to the above, from January 30 to August 3,

2018, the licensee failed to assure that operations of equipment and controls that had

been identified as important to safety in the Safety Analysis Report were limited to

trained and certified personnel or were under the direct supervision of an individual with

training and certification in the operation. Specifically, the licensees training program:

1. Failed to adequately train and certify the rigger/spotter position involved in the

important to safety downloading operation.

2. Failed to have adequate proficiency testing on the controls related to the load

indicating device and downloading operations for the VCT operator position.

The team determined that this violation was more than minor because the licensees

failure to establish an adequate training program contributed to the misalignment

incident on August 3, 2018. The team assessed and dispositioned this violation in

accordance with Section 2.2.2 of the NRC Enforcement Policy. The team characterized

the violation as a Severity Level IV violation. The NRC determined the issuance of a

Notice is appropriate because the actions to restore compliance have not been fully

developed and implemented, and the actions must be effective prior to beginning fuel

handling activities. (VIO 07200041/2018-001-03, Failure to establish adequate training

program)

The team identified that the simulator canister used for training and dry run

demonstrations had a specified outer diameter that was less than that of the actual spent

fuel storage canisters being downloaded into the vault. The simulator canister provided

approximately 0.75 inch more clearance than the actual canisters loaded with spent fuel.

This difference may be acceptable for the dry run activities; however, the difference was

not noted in any of the licensees training materials for rigger/spotters or the VCT

operators. This represents a situation of negative training that may have contributed to

the August 3, 2018, misalignment incident.

Conclusions

The important to safety lifting equipment and special lifting devices being used for dry

cask storage operations met applicable regulatory requirements.

Personnel lacked the proper training, proficiency testing, and certifications to operate

important to safety equipment identified in the HI-STORM UMAX SYSTEM FSAR,

Revision 4, dated August 14, 2017. This was identified as a violation of 10 CFR 72.190

requirements.

12

3.1.3 Charter Items 2 and 4

Inspection Scope

Evaluate the adequacy of the loading procedure(s) with respect to verification of the

movement, centering, lowering, and positioning the canister within the ISFSI vault and

procedure adherence. Interviews with personnel involved in the ISFSI loading

operations should be conducted to evaluate licensee and contractor communications

between crane/VCT operators, rigging and spotting staff, cask loading supervisors,

radiation protection staff, and licensee oversight personnel. Evaluate the adequacy of

pre-job briefings that may have taken place prior to fuel loading operations.

Based on the review of the procedures and interviews of personnel involved with

loading operations, evaluate the adequacy of procedure adherence.

The Special Inspection team reviewed Holtec Procedure HPP-2464-400, Multi-Purpose

Canister Transfer Operations at SONGS, Revision 15; Holtec

Procedure HPP-2464-600, Responding to Abnormal Conditions, Revision 6; SONGS

Procedure SO123-0-A7, Notification and Reporting of Significant Events, Revision 46;

and other applicable procedures related to the August 3, 2018, misalignment incident.

The team reviewed the pre-job briefing in use by the CLSs. The team discussed ISFSI

communications during downloading operations with the licensee and contractor staff.

Observations and Findings

Violation of 10 CFR 72.150, Procedures

The VCT is not equipped with a load-cell to provide the weight of the canister. A

hydraulic pressure indication for the lift beam could be used to provide a qualitative

means for determining if the slings are not supporting the canisters weight. This

pressure indication is displayed on the VCT HMI control panel.

The team identified examples of a violation of 10 CFR 72.150, Instructions, Procedures,

and Drawings. Holtec Procedure HPP-2464-400 provided direction and guidance for

verifying canister movement, canister centering operations, and for lowering the canister

into the vault. Many steps in the procedure provided direction without quantitative or

qualitative means to verify that important to safety steps had been achieved, including

detection of a loss-of-load condition and final verification that the canister had been fully

downloaded into the vault. For example, step 7.6.12 instructed the VCT operator to

continue to raise the VCT lift beam slowly until the full weight of the canister is on the

VCT.

However, there is no quantitative direct measurement for the VCT operator to determine

when the full weight of the canister is indicated on the VCT HMI control panel. The

procedure contained a note that the load on the VCT HMI screen may be used to

determine if downloader slings had become slack. However the procedure did not direct

the VCT operator to monitor the HMI control panel nor provide a qualitative or

quantitative value that would notify the VCT operator that the canister had become

misaligned and that the VCT was no longer bearing the load of the canister.

13

Holtec Procedure HPP-2464-400, step 7.6.23, states, if at any time the download slings

become slack prior to the canister being in the full down position then immediately stop

lowering the canister. During downloading operations there was only one position who

could determine whether or not the slings had gone slack. That position was the

rigger/spotter who is responsible to monitor the movement of the canister during

downloading operations from the elevated JLG basket. The rigger/spotter was

observing the slings during the August 3, 2018, downloading evolution. However, the

rigger/spotter was only observing the slings for slack at the top of the transfer cask.

The procedure did not provide adequate direction to the rigger/spotter to observe the

slings near the base of the VCT, which had become slack and were bundling up on the

ground. Additionally, the procedure did not provide direction for the rigger/spotter to

monitor the height of the canister in relation to the height of the lift beam.

Title 10 CFR 72.150, requires, in part, that the licensee prescribe activities affecting

quality by documented instructions or procedures of a type appropriate to the

circumstances and must include appropriate quantitative or qualitative acceptance

criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, from January 30 to August 3, 2018, the licensee failed to

prescribe activities affecting quality by documented instructions or procedures of a type

appropriate to the circumstances and include appropriate quantitative or qualitative

acceptance criteria for determining that important activities have been satisfactorily

accomplished. Specifically:

1. Procedure HPP-2464-400, Multi-Purpose Canister Transfer at SONGS,

Revision 15, step 7.6.23, failed to provide qualitative and quantitative directions

for the VCT operator to monitor control panel indications that would identify a

canister had become misaligned during downloading operation.

2. Procedure HPP-2464-400, Multi-Purpose Canister Transfer at SONGS,

Revision 15, step 7.6.23, failed to include adequate instructions for the

rigger/spotter to monitor the downloading slings for a slack condition.

The team determined that this violation was more than minor because the licensees

failure to prescribe adequate procedures contributed to the August 3, 2018,

misalignment incident. The team assessed and dispositioned this violation in

accordance with Section 2.2.2 of the NRC Enforcement Policy. The team characterized

the violation as a Severity Level IV violation. The NRC determined the issuance of a

Notice is appropriate because the actions to restore compliance have not been fully

developed and implemented, and the actions must be effective prior to beginning fuel

handling activities. (VIO 07200041/2018-001-04, Failure to provide adequate instructions

of procedures)

Communications

During downloading on August 3, 2018, radiation protection staff directed the CLS and

licensee oversight personnel to relocate to a low dose area off of the ISFSI pad. The

low dose waiting area was located approximately 150 feet away from the ISFSI

operations on the heavy haul path that is approximately 8 feet lower in elevation. From

the low dose area, neither the contractor nor licensee oversight staff could observe the

14

downloading activities. The NRC determined that the removal of oversight staff in an

effort to minimize radiation dose without other compensatory measures resulted in

inadequate supervisory oversight of important to safety lifting operations.

The communication protocols used by the CLS, VCT operator, and the rigger/spotter

was reviewed by the team. The CLS was in direct communications via radio and

headsets with the VCT operator and rigger/spotter. The radios provided adequate

communication in the noisy environment of the VCT. Communication between the CLS,

VCT operator, and the rigger/spotter during the downloading operation was informal.

The CLS did not request a reading of the HMI control panel to determine hydraulic

pressure and repeat-backs of the location of canister during the downloading process

were misunderstood.

Radiation Protection staff were not provided headsets for communications. Radiation

Protection staff were able to communicate concerns directly with the CLS, who could

communicate radiological concerns to workers, if necessary.

The licensees oversight personnel were not provided headsets during downloading

operations. The licensee did not provide direct oversight of downloading operations.

During the August 3, 2018, misalignment incident, neither licensee oversight nor

contractor supervision were in a position to directly monitor the downloading operations

or the actual condition of the canister.

Conclusions

Dry cask storage procedures did not provide adequate directions for how to determine

the downloader slings were slack. The downloading procedure did not include

qualitative or quantitative means for determining when a canister had become

misaligned. These procedure inadequacies were identified as examples of a violation

of 10 CFR 72.150 requirements.

No licensee or contractor oversight personnel were in direct visual observations of the

important to safety activities during downloading operations on August 3, 2018. All

personnel except the rigger/spotter and VCT operator left the ISFSI pad during

downloading operations. Licensee oversight was not a part of the communications

between the CLS, the rigger/spotter, and VCT operator during canister downloading

operations. Without adequate communications and visual observation, the licensee and

the contractor were unable to verify that important to safety dry cask storage activities

were adequately performed.

3.1.4 Charter Items 3 and 8

Inspection Scope

Review and evaluate the licensees immediate corrective actions taken after the

incident for adequacy and notifications to the NRC and safety assessments performed

immediately following the incident. Review the licensees inspection documentation

15

and/or analysis to determine whether the vaults divider shell experienced any damage

that would inhibit the component from performing its designed safety function.

Investigate the licensees procedures for reportability to the NRC and determine if the

licensee made the correct decision regarding notifications made to the NRC for this

incident.

The Special Inspection team reviewed the licensees initial assessment of the incident

through presentations and discussions provided by the licensee. The team reviewed all

condition reports and entries made into the licensees and dry cask storage vendors

corrective action programs regarding the canister misalignment incident, and the

condition of the divider shell and canister 29. The team reviewed the notification

requirements of 10 CFR 72.75 against the conditions experienced during the

August 3, 2018, misalignment incident and reviewed licensee Procedure SO123-0-A7,

Notification and Reporting of Significant Events, Revision 46.

Observations and Findings

Divider Shell Assessment

The licensee immediately stopped all dry cask storage operations following the

misalignment incident of August 3, 2018, pending a root cause evaluation to be

performed by their dry cask storage vendor, Holtec International. The licensee initiated

an apparent cause evaluation to determine if problems in its organization may have

contributed to the misalignment incident.

The misalignment incident was entered into the corrective action program by Holtec

as FCR 2464-1189. The Holtec FCR was initiated to investigate the August 3, 2018,

incident as a human performance issue. This FCR prompted the licensee to initiate

Action Request 0818-76588. This action request included an assessment of the

condition of the divider shell and canister.

Action Request 0818-76588 described the removal of paint/coating from the divider

shell. The action request concluded that the incidental transfer of divider shell coating to

the canister shell did not affect the canisters design functions of confinement, shielding,

structural, thermal, and criticality. Future actions to address coating presence will be

included in the licensees ISFSI aging management plan. The NRC team reviewed the

licensees assessment for the divider shell and concluded the component can perform its

safety functions. Additionally, the licensees plan to address future inspection of the

divider shells in its aging management program was acceptable.

Apparent Violation 10 CFR 72.75, Reporting

The team identified an apparent violation of 10 CFR 72.75 for late notification of 24-hour

reporting requirements involving important to safety equipment that was disabled or

failed to function as designed when the equipment is required by license condition and

no redundant equipment is available and operable to perform the required safety

function.

On August 3, 2018, during downloading operations associated with canister 29 the

licensee disabled the important to safety slings while downloading a canister (See

16

Section 2.1 and 2.2). The canister was placed in a potential load drop condition for

approximately 45 minutes before the licensee was able to restore the load onto the

important to safety slings, thereby restoring the redundant drop protection features.

After the incident, the licensee provided a courtesy notification to the NRC Region IV

office at approximately 4 p.m. CDT on the afternoon of August 6, 2018.

Section 10 CFR 72.75(d)(1), would have allowed for notification to be made to the

NRC Operations Center as late as 0800 EDT on Monday, August 6, 2018. The courtesy

notification made to the regional office did not satisfy the reporting requirements

of 10 CFR 72.75. During the August 6, 2018, call, the NRC informed the licensee that a

formal report to the NRC was likely required.

Notification of the NRC Operations Center did not occur until the licensee was prompted

by the NRC team on September 14, 2018. The condition was reported to the NRC

Headquarters Operations Center on September 14, 2018, at 1600 EDT (Event

Notification 53605).

Title 10 CFR 72.75(d)(1) requires, in part, that each licensee shall notify the NRC within

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery of any of the following events involving spent fuel in which

important to safety equipment is disabled or fails to function as designed when: (i) the

equipment is required by regulation, license condition, or certification of compliance to

be available and operable to mitigate the consequences of an accident; and (ii) no

redundant equipment was available and operable to perform the required safety

function.

Contrary to the above, from August 6 to September 14, 2018, the licensee failed to notify

the NRC after discovery of important to safety equipment being disabled and failing to

function as designed when required by the Certificate of Compliance to provide

redundant drop protection features to prevent and mitigate the consequences of a drop

accident and no redundant equipment was available and operable to perform the

required safety function.

The licensees failure to make the required 24-hour notification to the NRC within the

required timeframe was identified as an apparent violation of 10 CFR 72.75(d).

(AV 07200041/2018-001-05, Failure to make 24-hour notification)

Conclusions

The licensee concluded that the incidental removal of divider shell coating during

downloading operations did not affect the design functions for shielding, structural, and

thermal safety functions. The NRC has reviewed the licensees assessment for the

divider shell and has concluded the component can perform its safety functions.

Additionally, the licensees plan to address future inspection of the divider shells in their

aging management program is acceptable.

The licensee failed to make the required formal 24-hour NRC notification of the

August 3, 2018, event where important to safety equipment was disabled when the

equipment was required to mitigate the consequences of an accident and no redundant

equipment was available to perform the safety function. This failure was identified as an

apparent violation of 10 CFR 72.75(d) requirements.

17

3.1.5 Charter Item 6

Inspection Scope

Review the licensees root cause investigation results, to determine whether the review

thoroughly identified all contributing factors and that final corrective actions will be

adequate to prevent reoccurrence. Evaluate whether prior operational experience

relating to complications or issues associated with canister downloading operations was

identified and considered as part of the licensees root cause investigation and corrective

action development.

The Special Inspection team reviewed the causal evaluations that were performed for

the August 3, 2018, misalignment incident. Specifically, the team reviewed Holtec

Internationals Root Cause Analysis Report for the canister downloading incident and the

licensees Apparent Cause Evaluation to assess oversight effectiveness during the

August 3, 2018, download of canister 29.

Observations and Findings:

Holtec Internationals Root Cause Evaluation

The licensee directed Holtec to perform a causal evaluation as a follow-up item in

condition report action request 0818-76588 that the licensee initiated following the

August 3, 2018, misalignment incident. The Holtec causal evaluation identified one root

cause and five contributing causes:

• Root Cause: Holtec Management failed to implement appropriate program

improvements or the necessary level of oversight commensurate with the

complexity and risks associated with downloading operations.

• Contributing Cause 1: Inadequate content in procedures for recognizing special

conditions.

• Contributing Cause 2: Design review process did not ensure that unintended

consequences of design features were captured.

• Contributing Cause 3: Communication protocols with the chain of command

established during canister movement were not well defined.

• Contributing Cause 4: Holtec had not established a continuous learning

environment which promoted the use of internal and external operating

experience.

• Contributing Cause 5: Holtec Training Program did not fully establish

qualification or proficiency requirements for workers performing downloading

operations.

18

Southern California Edison Companys Apparent Cause Evaluation

The licensee initiated an apparent cause evaluation (ACE) to determine how its

organization may have contributed to allowing the August 3, 2018, loss-of-load incident

to occur. The licensees apparent causes were related to deficiencies in procedures,

training, and in oversight of contractor activities.

• Apparent Cause 1: Management failed to establish a process to ensure that site

dry cask storage procedures were technically accurate.

• Apparent Cause 2: Management failed to establish licensee and contractor

training to support procedure implementation.

• Apparent Cause 3: Management failed to sufficiently detail contractor Oversight

Specialist guidance.

• Contributing Cause 1: ISFSI project management was not routinely observing

dry cask storage operations.

• Contributing Cause 2: ISFSI project management was not consistently initiating

condition reports for dry cask storage operations that deviated from normal.

Both the licensee and Holtec causal evaluations reviewed many of the items identified

by the NRC team. Those items being: procedure adequacy; training adequacy;

adequacy of the corrective action program; oversight adequacy; and the inconsistent use

of operational experience during routine dry cask storage operations.

The causal evaluations assessed the severity of the canister misalignment incident. The

licensee determined that in the event of a canister drop accident from 25 feet into the

vault, there was no risk of radioactive exposure to the public. A publicly available

version of the licensees drop analysis summary is available in ADAMS (ADAMS

Accession No. ML18330A003). The NRC will continue to review the adequacy of the

causal analyses, corrective actions, and potential consequences during a follow-up

inspection which is planned to be performed before the resumption of fuel handling

activities.

Conclusions

The apparent and root causes for the August 3, 2018, canister misalignment incident

involved inadequate training, inadequate procedures, poor utilization of the corrective

action program, and insufficient oversight.

3.1.6 Charter Item 7

Inspection Scope

Review the licensees planned actions that will address the point loading condition that

was experienced by the affected canister. If applicable, review the licensees analysis

that demonstrated the canister will continue to perform as designed for continued

storage OR review licensees inspection plan to safely remove or lift the canister from

19

the vault to support inspection of the bottom of the canister to demonstrate the canister

did not receive any damage that would inhibit the component from continuing to perform

as designed.

Observations and Findings

The licensee performed an evaluation to demonstrate the canister continues to meet the

design and performance requirements described in the FSAR. The Special Inspection

team reviewed the licensees initial assessment of the canister 29 condition after the

misalignment incident.

The preliminary evaluation provided by the licensee stated that both the canister and

vault were not expected to have any physical damage that would exceed the pre-defined

limits used during receipt inspection and manufacturer acceptance testing. The NRC

requested additional analysis to ensure that the canister meets design requirements.

Additionally, the licensee is evaluating whether the canister will require increased

surveillance frequency for the aging management program. The licensee had not

completed the evaluation for NRC review prior to the NRCs inspection exit meeting.

This charter item will be reviewed during a future NRC inspection.

Conclusions

The licensee has chosen to provide an analysis to demonstrate that the potential

damage to canister 29 during the downloading would meet established acceptance

criteria. The NRC determined that additional analysis was required for the NRC to

ensure that the canister meets design requirements. This charter item will be reviewed

during a future NRC inspection.

3.1.7 Charter Item 9

Inspection Scope

As directed by regional management, observe resumption of fuel loading operations to

verify that corrective actions were effective in addressing deficiencies that contributed to

the incident. This should include evaluation of procedure and/or equipment

enhancements; review or observation of training and briefings provided to riggers, crane

operators, spotters and observers, supervisors and other personnel involved in fuel

loading operations.

Observations and Findings

The licensee suspended all fuel handling activities following the August 3, 2018,

misalignment incident. The NRC will review the licensees revised procedures, training

plans, equipment modifications, and performance testing (dry runs) of its dry cask

storage operations in a future inspection to determine the effectiveness of corrective

actions for the incident.

Conclusions

All associated corrective actions for the August 3, 2018, incident had not been

completely finalized or implemented by the licensee. The NRC will review the licensees

20

revised procedures, training plans, equipment modifications, and performance testing

(dry runs) of its dry cask storage operations during a future inspection to determine the

effectiveness of corrective actions for the incident.

3.1.8 Charter Item 10

Inspection Scope:

Determine if the inspection should be elevated to an Augmented Inspection Team (AIT)

inspection and promptly notify regional management of any recommendation to escalate

the special inspection to an AIT.

As a daily action item, the NRC Special Inspection Team reviewed NRC Inspection

Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors, Enclosure 2,

to determine whether any of the facts or details uncovered during the course of the

inspection met the deterministic criteria that would require the Special Inspection at

SONGS to be elevated to an AIT.

Observations and Findings

The deterministic criteria for an event to be elevated to an AIT effort are delineated in

Manual Chapter 0309. The Special Inspection Team did not identify any indication that

the August 3, 2018, misalignment incident at SONGS led to a radiological release.

Additionally, the incident did not involve the failure of the spent fuel canister, the release

of radiological contamination, or external radiation levels that exceeded 10 rads/hr.

Consequently, there was no need to elevate the inspection effort to an AIT. The teams

daily re-evaluation was communicated to Regional management during the week of

onsite inspection effort.

Conclusions

The NRC team did not identify any information that would have required the Special

Inspection to be elevated to an AIT effort.

4 Exit Meeting Summary

On September 14, 2018, following the onsite portion of the inspection, the inspectors

provided a debrief of the preliminary results to Mr. Tom Palmisano, former Vice President

and Chief Nuclear Officer and other members of the licensee staff. The licensee

acknowledged the issues presented by the NRC inspection team.

On November 1, 2018, the inspectors presented the final inspection results to Mr. Tom

Palmisano, former Vice President and Chief Nuclear Officer and other members of the

licensee staff. The licensee acknowledged the issues presented.

On November 8, 2018, the NRC performed a public webinar meeting to discuss the

inspection teams preliminary results.

21

SUPPLEMENTAL INSPECTION INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee Personnel

A. Bates, Regulatory and Oversight Manager

M. Morgan, Regulatory and Oversight

L. Bosch, Plant Manager

G. Carter, Westinghouse Project Manager

P. Chaudnary, Vice President of Operations, Holtec

J. Manso, ISFSI Sr. Project Manager

T. Palmisano, former Vice President Decommissioning and Chief Nuclear Officer

J. Pugh, Project Engineer

K. Rod, General Manager Decommissioning Oversight

J. Smith, Project Manager, Holtec

M. Soler, Vice President Quality, Holtec

INSPECTION PROCEDURES USED

IP 93812 Special Inspection

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

072-00041/2018-001-01 VIO Failure to identify and correct conditions adverse to

quality (10 CFR 72.172)

072-00041/2018-001-02 AV Failure to ensure redundant drop protection features

were available (10 CFR 72.212)

072-00041/2018-001-03 VIO Failure to assure that operations of important to safety

equipment were limited to trained and certified

personnel (10 CFR 72.190)

072-00041/2018-001-04 VIO Failure to provide adequate instructions or procedures

(10 CFR 72.150)

072-00041/2018-001-05 AV Failure to make 24-hour notification (10 CFR 72.75)

Discussed

None

Closed

None

Attachment

LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System

ADR Alternative Dispute Resolution

AIT Augmented Inspection Team

ANSI American National Standards Institute

AV Apparent Violation

ASME American Society of Mechanical Engineers

CFR Code of Federal Regulations

CLS Cask Loading Supervisor

FCR Field Condition Report

FSAR Final Safety Analysis Report

HI-STORM UMAX Holtec International Storage Module Underground Maximum Capacity

HMI Human-Machine Interface

IP Inspection Procedure

ISFSI Independent Spent Fuel Storage Installation

JLG Engine or Motor Powered Boom Lifting Device

NOV Notice of Violation

NRC U.S. Nuclear Regulatory Commission

MPC multipurpose canister

PEC Pre-decisional Enforcement Conference

RIC Rigger-in-charge

RPT Radiation Protection Technician

SL Severity Level

SONGS San Onofre Nuclear Generating Station

TS Technical Specification

VCT Vertical Cask Transporter

VIO Violation

VVM Vertical Ventilated Module or vault

2

INSPECTION CHARTER

TO EVALUATE THE NEAR-MISS LOAD DROP

EVENT AT SAN ONOFRE NUCLEAR

GENERATING STATION DATED

AUGUST 17, 2018

(ML18229A203)

Enclosure 3

August 17, 2018

MEMORANDUM TO: Eric J. Simpson, CHP, Health Physicist

Fuel Cycle and Decommissioning Branch

Division of Nuclear Materials Safety

W. Chris Smith, Reactor Inspector

Engineering Branch 1

Division of Reactor Safety

Marlone X. Davis, Transportation & Storage Safety Inspector

Inspections & Operations Branch

Division of Spent Fuel Management

THROUGH: Janine F. Katanic, PhD, CHP, Chief /RA/ LLH for

Fuel Cycle and Decommissioning Branch

Division of Nuclear Materials Safety

FROM: Troy W. Pruett, Director /RA/

Division of Nuclear Materials Safety

SUBJECT: INSPECTION CHARTER TO EVALUATE THE NEAR-MISS LOAD

DROP EVENT AT SAN ONOFRE NUCLEAR GENERATING

STATION

A special inspection has been chartered to review the licensees follow-up investigation,

causal evaluation, and planned corrective actions regarding the near-miss drop event

involving a loaded spent fuel storage canister at the San Onofre Nuclear Generating Station

(SONGS) Independent Spent Fuel Storage Installation (ISFSI) on Friday, August 3, 2018.

(License Nos. NPF-10 and NPF-15, Docket Nos. 50-361, 50-362 and 72-41).

CONTACT: Janine F. Katanic, PhD, CHP, FCDB/DNMS

(817) 200-1151

BACKGROUND AND BASIS

On Friday, August 3, 2018, at approximately 1:30 pm (PST), SONGS was engaged in

operations involving movement of a loaded spent fuel storage canister into its underground

ISFSI storage vault (HI-STORM UMAX storage system). As the loaded spent fuel canister was

being lowered into the storage vault using lifting and rigging equipment, the licensees personnel

failed to notice that the canister was misaligned and was not being properly lowered. The

licensee continued to lower the rigging and lifting equipment until it believed that the canister

had been fully lowered to the bottom of the storage vault. However, a radiation protection

technician identified elevated radiation readings that were not consistent with a fully lowered

canister. The licensee then identified that the loaded spent fuel canister was hung up on a

metal flange near the top of the storage vault, preventing it from being lowered, and that the

rigging and lifting equipment was slack and no longer bearing the load of the canister.

In this circumstance, with the important to safety (ITS) rigging and lifting equipment completely

down in the lowest position, the ITS equipment was disabled from performing its designed

safety function of holding and controlling the loaded canister from a potential canister drop

condition. The licensee reported that the canister was resting on a metal flange within the

storage vault. It was estimated that the canister could have experienced an approximately

17-18 foot drop into the storage vault if the canister had slipped off the metal flange or if the

metal flange failed. This load drop accident is not a condition analyzed in the dry fuel storage

systems Final Safety Analysis Report (FSAR).

In response to the discovery that the canister was not fully lowered, the licensee took immediate

actions to restore control of the load to the rigging and lifting devices. The estimated time the

canister was in an unanalyzed credible drop condition was approximately 45 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

in duration. The licensee regained control of the load, repositioned the canister, and lowered

the canister into the storage vault. The licensee halted all dry fuel storage movement

operations in order to fully investigate the incident and develop corrective actions to prevent a

recurrence. In addition, the licensee has shared the operational experience with another site

with a similar dry fuel storage system.

Region IV became aware of the SONGS near-miss incident on Monday, August 6, 2018, when

the licensee provided a courtesy notification and described it as a near-miss or near-hit

event. The reporting requirements of the incident are still being evaluated by the Region and

discussed with the licensee.

On August 7 and 16, 2018, Region IV and NMSS representatives participated in conference

calls with licensee representatives in order to gather additional facts regarding the

circumstances of the incident and the licensees investigation. Region IV is evaluating the

information provided by the licensee and is coordinating with the Division of Spent Fuel

Management, NMSS.

The NRC is chartering this special inspection pursuant to Management Directive 8.3, NRC

Incident Investigation Program, and NRC Inspection Manual Chapter 0309, Reactive

Inspection Decision Basis for Reactors.

The purpose of the inspection is to investigate the occurrence; interview personnel; observe

equipment; and review relevant documentation, including the results of the licensees

investigation and causal analysis, and development and implementation of actions to prevent

3

recurrence. The licensee has committed to not resume fuel loading operations until after this

special inspection and associated reviews are complete. Once the licensee has confirmed its

plans to resume fuel loading operations, inspectors will also observe the loading operations to

ensure that the corrective actions are adequate. These observations may be conducted as part

of this special inspection or as an independent inspection activity, as directed by regional

management.

SCOPE

The inspection should seek to address the following items at a minimum:

1. Identify and review all pertinent records, documents, and procedures related to the

licensees downloading operations at the ISFSI pad including but not limited to: worker

training and qualifications; rigging equipment qualification, testing, and preventative

maintenance; and lifting equipment qualification, testing, and preventative maintenance.

Evaluate the adequacy of the above noted procedures, worker training and equipment

testing and preparation.

2. Evaluate the adequacy of the loading procedure(s) with respect to verification of MPC

movement, centering the MPC over the ISFSI vault, lowering the MPC, and positioning

the MPC within the ISFSI vault. Interviews with personnel involved in the ISFSI loading

operations should be conducted to evaluate licensee and contractor communications

between crane/VCT operators, rigging and spotting staff, cask loading supervisors,

radiation protection staff, and licensee oversight personnel. Evaluate the adequacy of

pre-job briefings that may have taken place prior to fuel loading operations.

3. Review and evaluate the licensees immediate corrective actions taken after the event for

adequacy of notifications to the licensee and safety assessments performed immediately

following the event. Review the licensees inspection documentation and/or analysis to

determine whether the vaults divider shell experienced any damage that would inhibit the

component from performing its designed safety function.

4. Based on the review of procedures and interviews of personnel involved with loading

operations, evaluate the adequacy of procedure adherence.

5. Interview personnel associated with the event to develop a timeline to ensure the

licensees investigation contained all necessary information to identify all contributing

factors and develop adequate corrective actions.

6. Review the licensees root cause investigation results, to determine whether the review

thoroughly identified all contributing factors and that final corrective actions will be

adequate to prevent reoccurrence. Evaluate whether prior operational experience

relating to complications or issues associated with canister downloading operations was

identified and considered as part of the licensees root cause investigation and corrective

action development.

7. Review the licensees planned actions that will address the point loading condition that

was experienced by the affected canister. If applicable, review the licensees analysis

that demonstrated the canister will continue to perform as designed for continued storage

OR review licensees inspection plan to safely remove or lift the canister from the vault to

support inspection of the bottom of the canister to demonstrate the canister did not

4

receive any damage that would inhibit the component from continuing to perform as

designed.

8. Investigate the licensees procedures for reportability to the NRC and determine if the

licensee made the correct decision regarding notifications made to the NRC for this

event.

9. As directed by regional management, observe resumption of fuel loading operations to

verify that corrective actions were effective in addressing deficiencies that contributed to

the event. This should include evaluation of procedure and/or equipment enhancements;

review or observation of training and briefings provided to riggers, crane operators,

spotters and observers, supervisors and other personnel involved in fuel loading

operations.

10. Determine if the inspection should be elevated to an AIT and promptly notify regional

management of any recommendation to escalate the special inspection to an AIT.

GUIDANCE

The NRC is chartering this special inspection pursuant to Management Directive 8.3, NRC

Incident Investigation Program, and NRC Manual Chapter 0309, Reactive Inspection Decision

Basis for Reactors. The Manual Chapter and Management Directive identify Inspection

Procedure 93812, Special Inspection, for specific use in reviewing events. Planned Dates of

Inspection are September 10-14, 2018.

This inspection should emphasize fact-finding in its review of the circumstances surrounding the

near-miss canister drop event. Safety concerns identified that are not directly related to near-

miss drop event should be reported to NRC management for appropriate action.

Daily briefings with NRC management should occur to discuss the teams progress and

preliminary observations.

In accordance with Manual Chapter 0610, a report documenting the results of the inspection

should be issued within 30-45 days of the completion of the inspection.

This Charter may be modified should NRC inspectors find significant new information that

warrants review. Should you have any questions concerning this charter, please contact

Janine F. Katanic at 817-200-1151.

5