ML19114A018

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NRC-2019-000239 - Resp 1 - Interim. Agency Records Subject to the Request Are Enclosed
ML19114A018
Person / Time
Issue date: 04/17/2019
From:
NRC/OCIO
To:
References
FOIA, NRC-2019-000239
Download: ML19114A018 (22)
v • d • e


Text

NRC FORM 361 U.S. NUCLEAR REGULATORY COMMISSION (12*2000) OPERATIONS CENTER REACTOR PLANT EVENT NOTIFICATION WORKSHEET EN# 53858 NRC OPERATION TELEPHONE NUMBER: PRIMARY - 301-816-5100 or 800-532-3469', BACKUPS - [1st] 301-951-0550 or 800-449-3694',

[2nd] 301-415-0550 and (3rd] 301-415-0553 'Licensees v.tio maintain their own ETS are orovided these teleohone numbers.

NOTIFICATION TIME FACILITY OR ORGANIZATION UNIT NAME OF CALLER CALL BACK#

13:44 EST SONGS 2/3 2/3 Michael Johnson 949-368-6412 EVENT TIME& ZONE EVENTOATE POWER/MOOE BEFORE POWER/MOOE AFTER 14:05 PST February 1, 2019 Defueled Defueled EVENT CLASSIFICATIONS 1-Hr. Non-Emergency 10 CFR 60.72(b)(1) D (vXAJ Safe SID CapabDity AINA D GENERAL EMERGENCY GEN/AAEC D TS Deviation ADEV D (v)(B) RHR Capablity AlNB D SITE AREA EMERGENCY SIT/AAEC 4-Hr. Non-Emergency 10 CFR 50.72(b)(2) D (v)(CJ Conlrt>I of Rad Release AINC D ALERT ALE/AAEC D (I) TS Required SID ASHU D (v)(O) Accident Mitigation AINO D UNUSUAL EVENT UNU/AAEC D (ivXA) ECCS Discharge to RCS ACCS D (xii) Olfsite Medical AMEO D 50.72 NON-EMERGENCY (see next columns) D (ivXB) RPS Actuation (scram) ARPS D cxmJ Loss Comm/Asml/Resp ACOM D PHYSICALSECURITY (73.71) ODDO D (XI) Olls~e Nobfication APRE 60-Day Optional 10 CFR 50.73(a)(1)

D MATERIAL/EXPOSURE B??? 8-Hr. Non-Emeraency 10 CFR 50.72(bl(3) D Invalid Specified System Actuation AINV D FITNESS FOR DUTY HFIT D (B)(A) Degraded Condition ADEG Other Unspecified Requirement (Identify) 0 OTHER UNSPECIFIED REQMT. (see last column) D (iiXB) Unanalyzed Condition AUNA 0 10 CFR 72.75(d)(1) 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report NONR D INFORMATION ONLY NINF D (iv)(A) Specified Sy1tem Actuation AESF u NONR ni:~c~IPTION lndude: Systemsaffected, actuations and their initiating signals, cause,. effect of event on plant, actions taken or planned, etc. (Con/inue on back)

During follow-up reviews resulting from the Aug . 3, 2018 canister downloading event (EN#53605), Southern California Edison became aware of a condition where, during short periods of the canister transport process, the Vertical Cask Transporter (VCT) could have been operated without a supporting seismic analysis while transporting loaded canisters for storage. SCE has decided to conservatively report this issue.

The VCT is a mobile gantry crane that is used to transport and download fuel canisters into an Independent Spent Fuel Storage Installation (ISFSI) enclosure. Twenty-nine canisters have been downloaded into the San Onofre nuclear plant ISFSI in this manner since January 2018. The Holtec UMAX Certificate of Compliance requires that lifting of a loaded spent fuel canister must be performed with redundant (i.e., single-failure-proof) load drop protection features. Inherent in the definition is the ability to withstand seismic loading. SCE identified that although applicable rigging and downloading procedures were followed, a supporting seismic analysis should be developed for the short duration periods in the process where the canisters are transitioned to rigging .

Southern California Edison has directed its vendor, Holtec, to perform this further seismic analysis. While the additional analysis may conclude that the VCT is stable and functional during these transitioning periods, SCE will work with the vendor should modifications to the canister transport process become necessary.

SCE is making this notification in accordance with the requirements of 10CFR72.75(d)(1). There was no seismic event that resulted in damage to the VCT or a spent fuel canister during the fuel transfer campaign. All 29 spent fuel canisters are currently in safe storage within the ISFSI.

NOTIFICATIONS YES NO WILL BE NRC RESIDENT n 171 n ANYTHING UNUSUAL OR NOT UNDERSTOOD?

0 YES (Explain above) @ NO STATE(s) n 0 D DID ALL SYSTEMS

@YES 0 NO (Explain above) n LOCAL OTHER GOV AGENCIES D 171 0

D D

FUNCTION AS REQUIRED?

MOOE OF OPERATION UNTIL CORRECTEO Defueled IESTIMATEO RESTART DATE N/A IO ADomoNALINFO ONBACK YES @ NO MEDIA/PRESS RELEASE D 0 D (MMIOOIYYYY)

NRC FORM 361 (12*2000)

PAGE 1 OF 2

&II Handheld plus Features and benefits:

  • Overload counter
  • User settable 90db audible overload alarm
  • Multiple d isplay units - tonnes.

lbs, kg ond kN

  • 100Hz Peak hold
  • Pre-set tare
  • Wireless range 700m/2300ft The Handheld plus ls a rugged and versatile digital handheld display with a broad range of features and Also available with suitable for all Straightpoint load cell products. hazardous area approval

<G At the heart of the ergonomicaly designed Handheld plus Is a pov,ierful PCB providing industry leading fea1ures such as user setectable units of ITIE!OSll"e (tonnes, lbs. kg ond kN), pragroovnctJ(e audible overtood alCIITI\ peak hold, pre-set tare ord o user rescltl:tlle OYet1.ood counter.

This crucial ovenaod olcrm ~ e r Is a reqt.iremer( for maiy 9:lfety and cµility control departments. OS It keeps trod< of overlood events, oUowing the tood cell In question to be removed lrom seivice ATEX/IECEx lmmediotely, following the cciibratian voiding overtoad E!llef1I. The load Ex la II CTli Ga ceU in question con then be sent out for proper k!sting ond, if necessay. Certification number:

recalibration before r~emg sennce.

SW-HHPATEX IECEx SIR 15.0072X / Sire 15ATEX2196X The HHP Is suitable for comection via coble to any Stroightpoint cabled load cell product ond eosll.y ~ to any Olher When ordering ATEX/IECEx version of SW-HHP, manufacturers' load cell prodJct with a rn;/v a.rtput. In addition to the order using code: SW-HHP-ATEX stondad HHP the SWHHP Is 51.itoble for connection to any Pteose note: There 1s no audible otorm wrth ATEX Slraightpoint wireless tood cell. tl:Js a range of ~ to 700ml2300ft and is SI.Wied as stcrdard with the RodloUnk plus load cell.

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3H1 1'65 / NEMA ~X NIA Wni.ss24GH:z making the lifting industry a safer place INFORMATION ONLY 1814-AR171 -M0059 REV 0 Page 1 of 2

Supplier Status Stamp VPL 1814-AR 171 -M0059 Rev O QC : NIA No No*

0 DESIGN DOCUMENT ORDER NO. 0918--64884-1 x REFERENCE DOCUMENT-INFORMATION ONLY O VIRP IOM MANUAL MFG MAY PROCEED : DYES ONO []NIA STATUS - A status is required for design documents and is optional fof reference documents. Drawings are reviewed and appro¥ed for arrangements and conformance to specification only Approval does not reieve the submitter from the responsibihty of adequacy and suitability of design. materials, and/or equipment represented.

(]1. APPROVED

02. APPROVED EXCEPT AS NOTED - Make changes and resubmit
3. NOT APPROVED - Correct and resubmit for ~ N. NOT for field use RE /trsrto FLS.

Other: IA SCE DE(123) 5 REV 4 10/ 16 REFERENCE : SO l~ XXN- I0.1 INFORMATION ONLY 1814-AR171-M0059 REV 0 Page 2 of 2

OWireless Loadshackle Features and benefits:

  • Proprietary 2.4 GHz wireless
  • Error free data transmission
  • Industry Leading Wireless Range of 700m/2300ft
  • Environmentally sealed to IP67/NEMA6
  • Internal antennae
  • Remote on/off
  • Unrivalled resolution

, Unmatched battery Life or 1200hrs

  • Low headroom solution
  • Manufactured using leading brand shackles
  • Each WLS is supplied with a load-centring bobbin
  • Design validated by F.E.A
  • Bluetooth option is ovoiloble and is supplied with a free HHP App for iOS and Android Available from stock in capacities 3.25t to 120t cells. Logged data is captured in o .csv file format ond opens In and available up to 1,SSOt, the WLS Is MS Excel providing easy visual presentation, analysis of manufactured from Crosby's Industry leading togged data, and simple test certificate generation 2130 Carbon and 2140 Alloy Bolt Type Anchor The Wireless Loodshockle may also be used with Shackles (3.25te - 120te) and the GN H10 Alloy Stra1ghtpoint's SW.PTP software pockoge allowing the Bolt Type Anchor Shackle (200te on up).

operator to perform load tests at a sore distance ond generate real time test ccrt1f1cates on site.

Strolghtpoint's Wireless Loodshockle provides the perfect solution to limited headroom applications. Each Wireless Stroightpoint's Wireless Loodshockle utilises easily sourced AA Loodshockle Is proof tested, then equipped with a hard alkaline batteries and features advanced circuitry designed to anodised aluminium electronics enclosure. Contained within protect the unit from damage associated with incorrectly this aluminium enclosure Is a new Internal chassis providing installed batteries. This advanced circuitry extends battery life IP67/NEMA6 environmental protection even with the battery and the use of easily sourced alkaline batteries eliminates cover plate missing.

issues associated with rechargeable battery pock charging ,

failure ond replacement. Stroightpoint's huge range of tooling Featuring industry leading wireless technology and range of allows the engineers to calibrate In shackle for extra accuracy 700m/2300ft, the Wireless Loodshockle is supplied with on unlike many other load cell manufacturers update rott. of 3Hz and con be easily configured to run at industry leoding speeds of up to 200Hz Doto is transmitted A full array of wireless accessories ore olso available including wirelessty utilising the latest in IEEE 802.15.4 (2 .4 GHz) signal boosters, LED wireless scoreboards and base stations technology providing safe, high integrity, error free with analogue (4-20mA. 0-10v, 0-Sv) or digital (RS232/485, transmission of both static weight and dynamic load to o Modbus RTU, and ASCII serial communications protocol) wireless hondheld controller or wireless Windows PC dote outputs. There is no better choice than Strolghtpoint's Wireless logging software package. Stroightpoint's wireless data Loodshockle for limited headroom applications Logging software allows for simultaneous control display and real time data logging of up to 100 Stroightpoint telemetry load SEE SUPPLIER'S STAMP PAGE 3 S? INFORMATION ONLY making the lifting industry a safer place 1814-AR171-M0060 REV 0 Page 1 of 3

Also available with hazardous area approval r I

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SW-HHPATEX I IECEx SIR 15.0072X / Sire 15ATEX2196X I I

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Supplier Status Stamp VPL 1814-AR171-M0060 Rev O QC: NIA

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~ REFERENCE DOCUMENT- I FORMATION O Y 0 VIRP IOM MANUAL MFG MAY PR OCEED: YES ONO []NIA STATIJS - A status is required for design documents and 1s optional for reference docunents Dl-awings ~e re'liewed and approved for arrangements and conform.1nce to specification only Approval does not relieve the submitter from the respon<;blity of adequacy and suttab

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(] 1 APPROVED

02. APPROVED EXCEPT A NOTED - Make changes andresubnvt
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SCE OE(123) 5 REV 4 10/16 REFERENCE S0 12.J.XXIV- IO1 INFORMATION ONLY 1814-AR 171-M0060 REV 0 Page 3 of 3

SW-RWT Rugged tablet Features and benefits:

  • Light weight platform and ultro*mobl lty
  • Hot-swappable LI-Ion Battery Pock
  • OperoUng Environment

- MIL*STD-810G Certlfied

  • IP65 Rot* d protection from sand, dust and water

, V vld Dtsplay In any Environment

  • Windows 10 Enterprise LTSB (64*8 11)
  • Standard VO features - RS232. RJ45
  • 2 USB Ports and o M era SO slot J

The SW-RWT tablet Is the latest generation For In the field critlc*I Ufts fully-rugged tablets. Featuring an array of Integrated options, and a sleek, sophisticated Whethl!f us ng the Stro'ghtpoint SW-MWLC mu,tlple loodcell sohwore or our ground breaking Centre of Gravity system the design, the SW-RWT will change the way you look SW-RWT sets t standard for field moblUty at tablets. With a MIL-STD-810G rating and Windo 7 Pro, the SW-RWT can ga from the A full shift hot-swoppoble battery, lasting up to fourteen hours, boardroom to the work site without missing a maxim zes time In the fleld ond boosts productivity beat.

The brilliant outdOOf viewable, multi-touch dlsplay allows Excffdlng rugged standards seamless trans ton from Indoor to outdoor use Refined by over o de<:ode of real world c tome* feedbock and Supplied with carrying strops the SW-RWT Is on Ideal tablet for experience In the rugged space, the SW.RWT Is the most field applications running the Stroightpotnt suite of software rugged tablet in Its Closs. solutions.

Boosting a 5 foot drop roting. the SW-RWT's core construction features o lightweight magnesium alloy mid-frame In on ultra-portable form factor for the utmost rugged reUobllity Su lier Status Stamp_ _

Featuring MIL-STD-810G ond IP65, the SW RWT Is eng neered 1&1J-ARl71-M0061 I=~ 0 iSIGH DOCUMENT ORDER NO._,,_P9._l.r;;H,lx=,8&l--1_ _ _ __

to protect critical lih data under the most demanding REFERENCE DOCUMENT-INFORMATION ONLY VIRP IOM MANUAL.

conditions MFG MAY PROCEED: D YES NO []NIA STATUS

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  • 10 1 making the lifting industry a safer place INFORMATION ONLY 1814-AR171-M0061 REV 0 Page1 of 2

275 mm x mmm x 32 mm (108.

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Inlet quod< ore N2930 183 GHz Proc~sor with 216 GHz bo<>> t 101* 116 10) 1920*1200 rosotullon LEO hig!H>rightness Mo*Vicw* Technol ogy 10 points p,oj<<11ve copocilive touch Amb,ent Ught sensor Ro ,n ond glove mode 4GB DOR3 RAM/128 G6 SSD Wltldows 10 Enterprise LTSB 164-blt)

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  • Exlcmol GSM on1cnno input Audio Speaker / Oigllot M crophcne / Headset jock PAN lnleg,otod BT v40LE / v21 Cettulor !WWAN) S eno Wireless MC7304 / MC354 LTE HSPA+

GSM/GPRS Wireless LAN 802 lloc o/b/g n Dual Bond 2 415GHz lnlcgrotcd u-blox NEO-MSN GPS & GlONASS WAAS/EGNOS1MSA5< opob1c 5 Megop11et Camero , LEO flash Operat ng

  • 20 *c 10 60 ' C 1-4 ' F to 140 'FJ MIL*STO BIOG, Method 5015 Procedure II MIL-ST0-810G, Method 502 5 Procedure 11. 111 Storage -40 'C to 70 *c (-40 *F 10 158 'F)

MIL STD BIOG, Method 5015 Procedure I Ml *ST0-810G, Method 502 S Proccdu,o I Drop 26 drops lrom 1 22 m 14 ltl lo c oncrele MIL-ST0-810G Mclhod 5\6 6 Procedure IV V1brct1cn MIL- STD-810G, Method 514 6 Procedure I Sand & Oust IP65 IEC60529 Water IP6S, IEC60529 Hum dlty MIL-5TO*B10G Method 507 5 Procedure II Alt,ludc 4572 m / 15 000 ft MIL STD 810G Method 500 S Procedure I INFORMATION ONLY 1814-AR171-M0061 REV 0 Page2 of 2

  1. Change Package .. Supporting 72.48 Subject 1 DR 155192 0718-18311-2 Cask Tip-over in Cask Handling Pool 2 DR 758582 0818-76588-47 Potential D.image During lr1stallation (Comprehensive 72.48}

3 DR758584 0918-64884-6 Shackle- Based Load Monitoring System 4 DR 758630 0918-64884-7 Expanded to Note that LMS not Needed for Down Loading 5 DR 758614 0818-76588-49 Training Program Description Update to Reflect Improvements 6 DR 75_8641 0119-53875-5 Expanded to Support Response to Loss of LMS 7 DR 758711 0119-54369-2 Expanded Heavy Haul Path NOTES:

1. Changes 3, 4 and 6 ALL modify the same section of the 72.212 and, along with Change 2, began with Holtec EC0-5021-39Rl
2. Change Number 7 has an extra digit on first page. The correct number is on page 2. We'll correct in our Records. Also, as noted it supersedes a previous change we may have previously provided.

_1212!/J.018 U.S. Nuclear Regulatory Commissio11 Operatio11's Ce11ter Eve11t Report Pagel Independent Spent Fuel Storage Installation Event# 53798 Facility: SAN ONOFRE Notification Date / Time: 12/20/2018 13:56 (EST}

Licensee: SOUTHERN CALIFORNIA EDISON COMPANY Event Date/ Time: 12/19/2018 (PST}

Fae Type: ISFSI Last Modification: 12/20/2018 Region: 4 Docket #: 72-41 City: SAN CLEMENTE Agreement State: Yes County: SAN DIEGO License #: GL State: CA NRC Notified by: TIM CUSICK Notifications: RYAN ALEXANDER R4DO HQ Ops Officer: MARK ABRAMOVITZ Emergency Class: NON EMERGENCY 10 CFR Section:

72.75(d)(1) SFTY EQUIP. DISABLED OR FAILS TO FUNCTI SPENT FUEL TRANSFER VEHICLE OUTSIDE SEISMIC ANALYSIS LIMITS "As part of the reviews following the August 3rd 2018 canister downloading event (EN#53605}, SCE has identified events where the HI-PORT may have been operated outside the analytical assumptions of the seismic analysis while transporting a loaded canister in the HI-TRf\C. SCE has decided to conservatively report this issue.

"The HI-PORT is subject to requirements in the Certificate of Compliance that result in seismic restrictions on center of gravity and proximity to structures that could adversely affect the function of the HI-PORT along the haul route. SCE has concluded that during previous movements of loaded spent fuel canisters during 2018, the HI-PORT likely exceeded these procedural and analytical limits in some cases.

"Additional analysis is underway that may conclude that damage to the HI-PORT would not occur under these conditions. Nevertheless, this situation is being reported in accordance with 10CFR72. 75(d)(1) for an important to safety component that was disabled or failed to function. There was no seismic event that resulted in damage to the HI-PORT during the fuel transfer campaign. All 29 spent fuel canisters are currently in safe storage within the ISFSI. .

"NRC Region IV will be notified as SONGS does not have a NRC Resident Inspector."

NRC Followup Inspection Updated 4/9/20191:43 PM Issue Resolution I

Procedure Questions from the Followup Inspection 1 Why is it .OK to move the final 10°-20' to the CEC with HPP-2464-400R20 and HPP-2464-SOORB have been updated to the Belly Band removed? provide clarity on when the belly band is required (as dictated by the Seismic Analysis) 2 Proceduralize .a restriction for nighttime uploads HPP-2464-SOORS has been updated to add a restriction that Steps in Section 7.4 'MPC Transfer to HI-TRAC' shall not be performed while dark (after sunset and prior to sunrise). There shall be

enough time allotted for completion of upload operations (at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) prior to sunset.

3 Weather criteria for stopping download are not clear Section 6.2 in both HPP-2464-~00R20 and HPP-2464-SOORS have been updated to provide clarity on weather restrictions.

4 Procedure issues associated with loss of Section 7 .6.1 Note in HPP-2464-400R20 has been updated to state communications. Alternate methods allowed? "During MPC Downloading on the ISFSI pad, headsets will be provided for the CLS, VCT"operator, the Rigger-In-Charge of the load, personnel in aerial lift, the VCT Platform Rigger, an~ the SCE Representative. The CLS may specify additional requirements. If communications are lost, the work will be put into a safe condition until communications are restored."

5 2464-400 step 7.5.16 says to lift "as high as necessary." Section 7 .5.15 in HPP*2464-400R20 has been updated to state Aren't there seismic limits on lift height similar to in "ENSURE the HI-TRAC VW is raised no more than 52 inches over step 7.5.6? the ISFSI pad."

6 Definition of "MPC Damage" in the -600 procedure HPP-2464-GOORlO has been updated to remove Section 7.1 "MPC Damage" from Rev 9 of the procedure. A new section 7.22 has been added to address any conditions not specifically addressed in 600R10. This new section drives all other conditions into the Corrective Action Program to be appropriately addressed.

Page 1 of2

NRC Followup Inspection Updated 4/9/20191:43 PM Item# Issue Resolution 7 Step 6.2.1 and 6.40 of 2464-600 say shift manager HPP-2464-600R10 has removed prequesite and initial conditon to must be involved in transition to 600. Does this notify Shift Manager prior to entrance of this procedure. Steps prevent Immediate actions that would restore a safe throughout HPP-2464-600Rl0 have been revised to ensure work is condition from being performed? first placed in a safe configuration prior to notifying shift manager.

Remaining procedures HPP-2464-(100-500) have a revised precaution in Section 6 to clarify that If an abnormal event were to occur, work should be placed in a safe configuration and to refer to HPP-2464~600, Responding to Abnromal Conditions. The precaution also states once the work is in a safe conditon, the SM must be notified and involved in decision making before proceeding.

8 2464-400 - N/A'd steps for an entire section due to only Outstanding, words to add to rev 20 were added to the draft and traveling to the first row somehow removed prior to issuance. The AR is being reopened and the text was provided to the Holtec proc~dure writers 3/11/19 with the request for a PFCN. Projected resolution is that based on new requirements for travel to take place with the belly band installed no matter which CEC is the destination, it wil_l no longer be appropriate to N/A these steps and no change to the procedure will be required.

Page 2 of 2

From: Brookhart, Lee Sent Mcmday, March 04, 2019 5:08 PM To: MARK MORGAN; Kenneth Wilson; ALBERT BATES Cc: Simpson, Eric; Davis, Marlene; Wise, John; Smith, Chris

Subject:

Scratch/Scar Questions

  • Here are the consolidated questions from the end of the day:

Clarification needed for calculation Hl-2188437:

When the NRC team was onsite in Feb, we discussed SCE's path forward with the analysis. SCE mentioned that a Solidworks model was being developed, which would model the interferences and the maximum angle that would still permit a download of the MPC into the CEC. I understood that Solidworks model would include a parametric study that examined the effects of:

  • Tolerance of min/max MPC & CEC diameter
  • Greatest pitch (eccentricity and out-of-plumb) of CEC
  • Etc. (GDT stackup considerations)

In addition, I thought the actual Solidworks model would be included in the calculation.

None oftne above items are discussed in Hl-218ij437.

The determination of the angle, as presented in Appendix Band C of Hl-2188437, derives a maximum angle deviation of 1°.

It's also interesting that this 1° derived from Hl-2188437 is the same angle predicted by the prior paper D5469 on page 3/7 .

. Questions:

1.) How was 1° angle derived? And how is it correct in both cases (shield ring and inner seismic restraint)?

  • Is there a solidworks model that shows the inputs used, can we review the inputs or solidworks model?

The determination of the angle of contact is critical, because it is the driving term in Archard's equation used in both the HI calc and the DS paper.

Despite the fact that the D5469 paper and Hl-2188437 both derive a maximum angle deviation of 1°, the HI calculation computes a fo~ce of 2136 lbf vs the DS paper force of 2411 lbf.

2.) Why is there a disparity (2136 lbf vs 2411 lbf)?

1

For record keeping purposes, my on-going list is:

2 BB Questions (submitted in email by me on Fri) 2 ECO Questions (submitted via email by me)

And now 2 Seismic Cale Questions.

Thanks Lee 2

From: Brookhart, Lee Sent: Tuesday, March 05, 2019 5:28 PM To: MARK MORGAN; ALBERT BATES; Kenneth Wilson Cc: Piotter, Jason; Simpson, Eric; Smith, Chris; Wise, John; Davis, Marlone

Subject:

RE: Questions status at end of Tues Sorry I spoke too soon. We have one new question:

Test Report Question:

1.) In Hl-2188450 (scratch test report), please describe the method used to determine the scratch depth.

Specifically, what measurement and test equipment was used, was it controlled M&IE an.d have a current calibration?

  • So the total now is:
  • 2 open questions on BB calc.

2 open questions on ECO .

5 open questions on Scratch/Scar Cale 1 open question ori the Test Report Thanks Lee From: Brookhart, Lee Sent: Tuesday, March 05, 2019 5:18 PM To: MARK MORGAN <Mark.Morgan@sce.com>; ALBERT BATES <Al.BATES@sce.com>; Kenneth Wilso~

<Kenneth.R.Wilson@sce.com>

Cc: Piotter, Jason <Jason.Piotter@nrc.gov>; Simpson, Eric <Eric.Simpson@nrc.goV>; Smith, Chris <Chris.Smith@nrc.gov>;

Wise, John <John.Wise@nrc.gov>

Subject:

Questions status at end of Tues

!'have not received any new questions to add to the on-going list.

Status at end of Tuesday is:

2 open questions on BB calc.

2 open questions on ECO 5 open questions on Scratch/Scar Cale Thanks Lee

From: Brookhart, Lee Sent:* Wednesday, March 06, 2019 2:15 PM To: MARK MORGAN; ALBERT BATES; Kenneth Wilson Cc: Smith, Chris; Piotter, Jason; Davis, Marlane; Simpson, Eric; Wise, John; Call, Michel .

Subject:

Test Report Question Attachments: SKM_C45819030614560.pdf Question on the Test Report:

The summary section of the test report is vague. So vague, that I have to come up with my own conclusion and try to place the test report outcome into my own perspective.

5.0 Summary*section states:

Simulation of a high load contact force interaction between a 304 SS plate and SA 240 Type 316/316 L surface conducted at Orrvilon suggests a worse case scratch depth of 0.008" occurring_ on the 304 SS plate as in Trial 14.

Since there is no other guidance in the summary section. I am left to attempt to use the numbers from Trial 14 to see if it bounds the prediction as presented in Hl-2188437 using Archard's equation.

So using Trial 14 inputs:

F =5000 lbf HBr =86.6 N/mm2 Width =0.57 in The maximum depth of a possible sc*ratch per Archards wear equation = 0.00698" or 6.98 mils (see my attached equation)

However, the test recorded a scratch depth of 0.008" (8 mils). Sp now I am confused, I thought the reason for the tests was to show the calculation was conservative.

Unless my math is wrong .... which it very well could be, the test summary (as presented in the Summary Section) does not seem to bound the conservative equation.

Question on Test Report:

2. Can SCE provide an enhanced summary section on how the test data can be used to bound the calculations and evaluation presented in Hl-2188437?

If I had a math error please let me know and I will retract the question, Thank you Lee 1

From: Brookhart, Lee Sent Monday, December 10, 2018 2:57 PM To: MARK MORGAN; ALBERT !3ATES Cc: Bloodgood, Michael; Simpson, Eric

Subject:

Corrective Actions Things I thought would be up on Certrec to support returning to FTO.

No particular order:

RCE-CA-3 RCE-CA-4 RCE~CA-8 RCE-CA-18 RCE-CA-19 RCE-CA-20 RCE-CA-29 RCE-CA-14 ACE-CA-02 ACE-CA-05b ACE-CA-11 ACE-CA-12 ACE-CA-03 ACE-CA-12 ACE EFR-01 (for effectiveness of downloading changes and dry runs)

ACE EFR-02 (for effectiveness of downloading reviews performed by OS during dry runs)

CC CA-01 CC CA-02b CC CA-03 CC CA-04a CC CA-04b 1

From: Brookhart, Lee Sent: Tuesday, December 11, 2018 1:56 PM To: MARK MORGAN; ALBERT BATES Cc: Smith, Chris; Bloodgood, Michael; Simpson, Eric

Subject:

RE: Issues anp or open request Updated to. add Question #3. Team I have to leave early, but if you have new questions to add by the end of the day. Feel free to add to the list.

Lee From: Brookhart, Lee Sent: Monday, December 10, 2018 5:27 PM To: 'MARK MORGAN' <Mark.Morgan@sce.com>

Cc: 'ALBERT BATES' <AL.BATES@sce.com>

Subject:

Issues and or open request Issues or Open Requests:

f.) RCE-CA-21 is missing the right attachment, RCE CA-07 (HPP-008) is attached not a lift risk matrix.

2.) RCE-CA-08 and ACE CA-01 does not include the information needed to perform our review. Items that are needed:

  • SCE 72.48 SCN 0918-64884-6 (for new equipment), please provide an explanation why this screen was not included as part of the package.
  • Holtec 72.48 Screen to implement new equipment o If Holtec states the FSAR change {EC0-5021-39) was the screen used to incorporate the equipment, then the NRC would have concerns With their screen because adding equipment in-line with the canister load, in which the failure of such equipment could create ail accident {drop), was not addressed in that 72.48 screen.
  • Purchase Spec for the ITS load shackles
  • Manufacturer's Manual for Load Shackles
  • Maintenance and/or Calibration schedule for load shackles
  • Load testing documentation for the Load Shackles
  • Disposition of the other new equipment shdwn iii HPP-2464-400 Attachment 8.6

{intermediate slings, master links, other shackles, etc.)

  • We would expect ALL the new equipment in-line carrying the load of the MPC be designated and treated as ITS just like the MPC cleats and Downloading slings o As such, we would expect to see Purchase Specs/Dedication packages, Design Change Package that discusses the new equipment, load testing documentation, and an explanation of how the equipment has been included into the current maintenance program for tracking required inspections and calibrations.
  • Regarding the camera and tail tell rope **

o The load monitoring system (as described in the new FSAR change), does not address the camera and rope

From: Brookhart, Lee Sent: Thursday, December 13, 2018 10:00 AM To: MARK MORGAN; ALBERT BATES Cc: Smith; Chris; Bloodgood, Michael; Simpson, Eric

Subject:

RE: Issues and or open request Well Disregard most of #7 from yesterday. I had not read Job Guide "O~ersight Situational Awareness" that covered reviewing training and qualifications for every pre-job brief attended.

Should have finished my review of the package before asking that question, apologies.

After finding the Pre-job brief section and finishing. my review, these Job Guides for your OS to follow is a encompassing document and noted as strength.

See updates below.

From: Brookhart, Lee Sent: Wednesday, December 12, 2018 5:23 PM To: 'MARK MORGAN' <Mark.Morgan@sce.com>; 'ALBERT BATES' <AL.BATES@sce.com>

Cc: Smith, Chris <Chris.Smith@nrc.gov>; Bloodgood, Michael <Michael.Bloodgood@nrc.gov>; Simpson, Eric

<Eric.Simpson@nrc.gov>

Subject:

RE: Issues and or open request Updated the ongoing list below.

From: Brookhart, Lee Sent: Tuesday, December 11, 2018 1:56 PM To: 'MARK MORGAN' <Mark.Morgan@sce.com>; 'ALBERT BATES' <AL.BATES@sce.com>

Cc: Smith, Chris <Chris.Smith@nrc.gov>; Bloodgood, Michael <Michael.Bloodgood@nrc.gov>; Simpson, Eric

<Eric.Simpson@nrc.gov>

Subject:

RE: Issues and or open request Updated to add Question #3. Team I have to leave early, but if you have new questions to add by the en9 of the day. Feel free to add to the list.

  • Lee From: Brookhart, Lee Sent: Monday, December 10, 2018 5:27 PM To: 'MARK MORGAN' <Mark.Morgan@sce.com>

Cc: 'ALBERT BATES' <AL.BATES@sce.com>

Subject:

Issues and or open request Issues or Open Requests:

1.) RCE-CA-21 is missing the right attachment, RCE CA-07 (HPP-008) is attached not a lift risk matrix.

o Please explain what classification has been applied to these components*

(camera and rope). Are they pieces of equipment required to ensure a potential drop is not credible?

3.) ACE CA-04-400 and ACE CA-01 procedure implementation does not. See attached photo. The NOTE direction (in ACE CA-04-400) no longer specifies what is required when the camera fails or malfunctions. This is something the NRC will need to understand and what contingencies will be required to be implemented in order to continue downloading. I would think those contingencies would sp~cified in the procedure and would not be subject to what the Holtec PM arid SCE oversight on the particular job decide.

From Lee 2

From: Brookhart, Lee Sent: Tuesday, March 05, 2019 8:52 AM To: MARK MORGAN; ALBERT BATES; Kenneth Wilson Cc: Piotter, Jason; Davis, Marlone; Smith, Chris; Simpson, Eric; Wise, John

Subject:

RE: New Question for Scratch Cale.

Attachments: Cranes-Sl ings Item 3 Downloader Slings Certs.pdf Thinking on it some more . You would need two calcs 1.) What happened in the past with 62 .5 ft slings rated at 1116,000 lbs 2.) What will happen in the future using the 58 ft 6" slings with 4ft intermediates Where did Holtec get 53ft-6inches slings at 140,000 lbs used in the calc?

Lee From: Brookhart, Lee Sent: Tuesday, March 05, 2019 8:27 AM To: MARK MORGAN <Mark.Morgan@sce.com>; ALBERT BATES <AL.BATES@sce.com>; 'Kenneth W ilson'

<Kenneth.R.Wilson@sce.com>

Cc: Plotter, Jason <Jason.Piotter@nrc.gov>; Davis, Marlone <Marlone.Davis@nrc.gov>; Smith, Chris

<Chris.Smith@n rc.gov>; Simpson, Eric <Eric.Simpson@n rc.gov>; Wise, John <John.Wise@nrc.gov>

Subject:

New Question for Scratch Cale .

Sorry, I started this question late yesterday but didn't finish it.

Scratch Cale Question:

(1 and 2 were submitted yesterday) 3.) Section A.2 .2 "Stiffness of Slings" uses the wrong sling lengths to show contact at the base seam weld is not possible. It states the slings used by SONGS are 53 ft 6". But the purchase orders state SONGS uses 58ft long sling and 4ft. Intermediate slings to perform downloading operations. Where would the true "hang-up and release* contact point be for the operations at SONGS using the slings that were purchased?

Thanks Lee

2.) RCE-CA-08 and ACE CA-01 does not include the information needed to perform our review. Items that are needed (updated from call):

  • SCE 72.48 SCN 0918-64884 -6 (for new equipment), please provide an e><planation why this screen was not included as part of the package . Provide revised 72.48 and revised NECP

~oltec 72 .48 Screen to implement new equipment o If Holtoc states tho FSAR change (ECO 5021 39) was tho screen used to incorporate the equipment, then the NRG would have concerns with the ir screen because adding equipment in lino with tho canister load, in which tho failure of such equipment could create an accident (drop), was not addressed in that 72.48 screen .

  • Purchase Spec for the ITS load shackles o Purchase Spec for other new ITS equipment (other shackles, master link, intermediate sling)
  • Or if not Purchased as ITS , tho Dedication package to accept the load shackles as ITS o Was the Load Shackle Pin from Holtec's approved vendor?
  • Manufacturer's Manual for Load Shackles
  • Maintenance and/or Calibration schedule for load shackles, Exelon Labs cal sheet
  • Load testing documentation for the Load Shackles o Load testing documentation for other new equipment (other shackles, master link.

intermediate slings)

  • Disposition of the other new equipment shown in HPP 2464 400 Attachment 8.6 (intermediate slings, master links, other shackles. etc.)
  • We would o><pect ALL tho now equipment in lino carrying the load of the MPG be designated and treated as ITS just like the MPG cleats and Downloading slings o As such , we would expect to see Purchase Specs/Dedication packages, Dosi9R Change Package that discusses the new equipment, load testing documentation, aAtl-aR explanation of how the equipment has been included into the current maintenance program for tracking requ ired inspections and calibrations . (Still want to understand this)
  • Regarding the camera and tail tell rope o The load monitoring system (as described in the new FSAR change) , does not address tho camera and rope o Please explain what classification has been applied to these components (camera and rope) . Aro they pieces of equipment required to ensure a potential drop is not crodibl&?-
  • What is required if load shackle digital reading stops working during download since new FSAR states in Section 9.1.1 "load monitoring system will be used during MPC downloading" 3.) ACE CA-04-400 and ACE CA-01 procedure implementation does not . See attached photo. The NOTE direction (in ACE CA-04-400) no longer specifies what is required when the camera fa ils or malfunctions. This is something the NRC will need to understand and what contingencies will be required to be implemented in order to continue downloading. I would th ink those contingencies would specified in the procedure and would not be subject to what the Hallee PM and SCE oversight on the particular job decide .

4.) HPP-400 Step 7.6.44C/7 .6.49 states "Visually Verify the VCT lift towers lower evenly." This is not a quantitative value . What constitutes "evenly," at what value difference between the two towers wou ld SONGS expect VCT operator to stop operations because towers are not "evenly".

5.) Copy of new 72.212 evaluation with the 72.48 screen that made the change 6.) Copy of new procedure titled Holtec/SCE Event Response 7.) ACE CA-05a : Comment:

  • I think it would be valuable to add in the MPC welding activity to verify < 3/8" weld material laid in each weld pass.

Do want 4 paper copies of all Job Guides for NRC to follow and observe SCS performing job duties during dry runs next week 2

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